Peer Consultation Workshop on Approaches to Polycyclic Aromatic Hydrocarbon (PAH) Health Assessment


m	United States

Environmental Protection
Agency

Peer Consultation Workshop
on Approaches to Polycyclic
Aromatic Hydrocarbon
(PAH) Health Assessment

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EPA/63 5/R-02/005
January 2002

Peer Consultation Workshop on Approaches to Polycyclic Aromatic
Hydrocarbon (PAH) Health Assessment

National Center for Environmental Assessment
Office of Research and Development
U.S. Environmental Protection Agency
Washington, DC

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NOTICE

This document has been reviewed in accordance with U.S. Environmental Protection
Agency (EPA) policy and approved for publication. Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.

This report was prepared by Versar, Inc. and BR Stern Associates, EPA contractors
(Contract No. 68-C-99-23, Task Order No. 55), as a general record of discussion for the peer
consultation meeting. This report captures the main points of scheduled presentations, highlights
discussions among the reviewers, and documents the public comments provided at the peer
review meeting. This report does not contain a verbatim transcript of all issues discussed during
the peer review, and it does not embellish, interpret, or enlarge upon matters that were
incomplete or unclear. Except as specifically noted, no statements in this report represent
analyses by or positions of EPA, Versar, Inc., or BR Stern Associates.

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CONTENTS

EXECUTIVE SUMMARY	iv

1.0 INTRODUCTION	1

1.1	Workshop Purpose	1

1.2	Workshop Participants	1

2.0 SUMMARY OF OPENING REMARKS AND PRESENTATIONS	2

2.1	Welcome: Introduction and Background 	2

2.2	Overview of PAH Risk Assessment Practices in EPA Program Offices	2

2.2.1	Office of Air and Radiation (OAR)	2

2.2.2	Office of Solid Waste and Emergency Response (OSWER)	3

2.3	Background on Current Approaches to PAH Health Risk Assessment	4

2.3.1	Surrogate Approach	4

2.3.2	Comparative Potency Approach 	5

2.3.3	Relative Potency Factor Approach 	6

3.0 SUMMARY OF KEY COMMENTS AND RECOMMENDATIONS	8

3.1	Surrogate Approach	8

3.2	Comparative Potency Approach 	9

3.3	Relative Potency Factor Approach 	9

3.4	Cross-Cutting Issues 	10

4.0 DETAILED PRESENTATION OF INDIVIDUAL DISCUSSION TOPICS	12

4.1	Surrogate Approach	12

4.2	Comparative Potency Approach 	16

4.3	Relative Potency Factor Approach 	19

5.0 SUMMARY OF OBSERVER COMMENTS	27

6.0 ACTION ITEMS: FUTURE INFORMATION AND RESEARCH NEEDS 	28

APPENDIX A LIST OF PARTICIPANTS
APPENDIX B LIST OF OBSERVERS
APPENDIX C AGENDA
APPENDIX D PRESENTER OVERHEADS

APPENDIX E WORKSHOP ON APPROACHES TO POLYCYCLIC AROMATIC
HYDROCARBON (PAH) HEALTH ASSESSMENT - DISCUSSION
DOCUMENT

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Peer Consultation Workshop on Approaches to
Polycyclic Aromatic Hydrocarbon (PAH) Health Assessment

EXECUTIVE SUMMARY

The National Center for Environmental Assessment (NCEA) of the U.S. Environmental
Protection Agency (EPA) sponsored a two-day peer consultation workshop, entitled "Peer
Consultation Workshop on Approaches to Polycyclic Aromatic Hydrocarbon (PAH) Health
Assessment" on October 24-25, 2001, in Arlington, Virginia. The objectives of the workshop
were to: (1) evaluate the extent to which each of the three available approaches to PAH health
risk assessment is supported by the current scientific literature; and (2) assess how well each
approach addresses the range of exposure situations and monitoring data encompassed by EPA
program offices. The workshop focused on the extensive carcinogenicity literature for PAHs.
Ten experts in polycyclic aromatic hydrocarbon (PAH) toxicology and chemistry, and risk
assessment of chemical mixtures, provided their individual opinions on existing approaches and
recommended additional analyses and research; consensus was not required. Dr. Joe Mauderly
served as chairperson and moderator. Versar, Inc., provided logistic support and prepared a
summary report of the proceedings.

Representatives from EPA's Office of Air and Radiation (OAR) and Office of Solid Waste and
Emergency Response (OSWER) briefly described how their respective program offices handle
PAH risk assessment. EPA scientists from the Office of Research and Development (ORD)
provided background summaries on three available approaches to PAH health risk assessment:
(1) surrogate approach; (2) comparative potency approach; and (3) relative potency factor
approach. Following these opening presentations, the experts discussed the strengths and
weaknesses of each approach, noting the scientific and practical considerations as well as future
data needs. Summarized below is a brief description of the approaches that were discussed and
the main comments and suggestions provided by the participants.

Surrogate Approach

The surrogate approach was described as a whole mixture approach based on the assumption that
any mixture of PAHs in the atmosphere (or mixture of concern) is merely a dilution of a
"surrogate" mixture of PAHs, the "surrogate" being a potent PAH-containing mixture that has
been well characterized both chemically and toxicologically. Under this assumption, the risk
from any PAH mixture of concern is directly related to the extent of this dilution. The extent of
dilution is based on examining the ratios of several PAHs common to both the mixture of
concern and the surrogate mixture. The surrogate approach is based on the Agency's mixtures'
guideline which recognizes and endorses whole mixture approaches. Fundamental difficulties of
this approach include the appropriate choice of a "surrogate" whole mixture and evaluation of
"sufficient similarity" to the mixture of concern, based on EPA's mixtures' guidelines. Major
advantages to the surrogate approach include: (1) a mixture (as compared to single components)
is used as the reference compound, and (2) the composition and toxicity of the surrogate mixture
as a whole is known. Several experts stated that the surrogate approach exhibits considerably
less uncertainty than the other approaches, mainly because the surrogate is a mixture whose
individual components are known and potential interactions among components are included in

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toxicity characterization. As long as the chosen "surrogate" mixture is more potent than the
mixture actually being evaluated, this approach would also be more conservative. For this
reason, some experts considered it to be the preferred approach. The key assumption underlying
the use of this approach is a judgment of "sufficient similarity" of the mixture of interest to the
surrogate mixture. It was recommended that analysis be conducted on a range of complex
mixtures to determine composition and the degree of similarity/difference among mixtures.

Some, but not all, participants considered a limitation of this approach to be the choice and use
of only one reference mixture, i.e., "surrogate." One participant considered the principal
limitation of the approach, in its present form, to be that it is only intended to account for the
PAH fraction of a complex mixture, specifically the unsubstituted PAH fraction, and other
components of the mixture (including nitro and other substituted PAHs) are not accounted for. It
was also noted in the example given for this approach that the animal bioassay data are for
inhalation exposure only, and the approach might not be currently useful (at least without further
refinement) for assessments in which ingestion and dermal routes of exposure are important.
Some participants recommended that other reference mixtures be identified and characterized,
and that the use of additional indicator compounds for estimation of potency be explored.
Suggestions for other indicator compounds included: (1) the group of 7 PAHs classified as
probable human carcinogens currently utilized in the relative potency factor approach; (2) the 4-
to 7-ring PAH fraction; (3) total organic carbon (TOC); and (4) total PAH mass.

Comparative Potency Approach

The comparative potency approach was initially developed by EPA to evaluate the adverse
health effects of diesel fuels in the 1980's, when it was assumed that the entire automobile fleet
would eventually be dieselized and that there would be widespread human exposure to diesel
emissions. The underlying assumption of the comparative potency method is that similar
mixtures in a data set (e.g., combustion mixtures) act in a similar manner toxicologically, and
that the relative potency of two such mixtures in an in vivo or in vitro bioassay is directly
proportional to the relative potency in humans, represented by k, a scaling factor. For a mixture
of interest of unknown potency considered to be a member of this group of similar mixtures,
human cancer potency can be estimated by applying the scaling factor to short-term bioassay
data. This assumption was examined for three complex organic emission products (from
cigarette smoke, coke oven emissions, and roofing tar) that had previously been shown to be
associated with the induction of respiratory cancer in exposed human populations. For these
three emission products, data from the Senear mouse skin tumor initiation assay was most highly
correlated with unit risk estimates for lung cancer. Inhalation unit risk estimates derived from
occupational epidemiology studies on coke oven emissions, roofing tar, and cigarette smoke
were used to rank these three mixtures, normalizing to coke oven emissions, and these rankings
coincided with the animal bioassay data. The human cancer potency for diesel emissions was
subsequently determined by using cancer data from a rat inhalation study, multiplied by the
scaling factor. Using this approach, the relative potency of diesel emissions was less than roofing
tar but more than cigarette smoke.

The strength of this approach is based on the concept that the potency of a PAH-containing
mixture can be estimated without having to either identify or quantify individual PAH
components. To use this approach, a simple and low-cost animal assay would be performed with

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the mixture of interest and the results extrapolated to humans, using a scaling factor determined
from a set of similar mixtures. However, there must be sufficient evidence to determine that the
mixture of interest is: (1) a potential human carcinogen and (2) sufficiently similar to the set of
mixtures used to develop the scaling factors.

The participants acknowledged that the advantage to this approach is that the toxicity for the
whole mixture is characterized, whether or not the composition of the mixture is known. The
key assumption underlying this approach is that the ratio between the potency for the same
mixture in an animal bioassay and the human cancer risk is constant for different PAH-
containing mixtures. Major issues associated with the approach include: (1) it cannot be used
with mixtures from multiple or unknown sources; (2) there is considerable uncertainty about the
reliability and validity of the lung cancer epidemiology studies which are available to derive
scaling factors, because of the confounding effects of smoking; and (3) this approach is currently
based on inhalation exposure data and might only be applicable to the inhalation route because
no human oral exposure studies are available. Most participants were skeptical about the use of
physiologically-based pharmacokinetic (PBPK) models for route-to-route extrapolation because
of the difficulty of characterizing the toxicokinetics of a complex mixture containing numerous
compounds. Route-to-route extrapolation of data was not recommended, based on the current
state of the science.

Relative Potency Factor Approach

The relative potency factor approach is a component approach in which the carcinogenic
potencies of selected PAHs relative to an index compound (e.g., benzo(a)pyrene (BaP)) are
determined, and individual PAH risks are summed to yield a cancer risk estimate for the whole
mixture. Current EPA provisional guidance (EPA, 1993) utilizes this approach to assess the risk
associated with PAH mixtures. The key assumptions underlying the use of this approach are that
individual PAH risks are additive and that the sum of the risks of selected PAHs adequately
characterizes the risk for the entire PAH component of the mixture. The advantage of this
approach is that it is practical for exposure situations in which the source and the composition of
the mixture are unknown. However, many participant agreed that this was the least
scientifically-defensible approach, and that any approach that utilizes the toxicity of a mixture as
a whole is preferable to the use of the relative potency factor approach. The major issues
associated with this approach are that it is not based on a reference PAH mixture with known
toxicity (animal or human), that there are no human toxicity data on any of the individual PAHs,
and that the assumption of additivity of individual PAH toxicity may not be accurate.

Cross-Cutting Issues

While much of the experts' discussion focused on the three approaches, there were many issues
raised that pertained to all three methods and the challenges facing PAH risk assessment in
general. It was noted frequently that most data on the carcinogenicity of PAHs comes from
mouse skin tumor initiation studies. Some participants recommended that chronic exposure
studies be conducted on key PAHs and PAH mixtures, and that oral potency should be based on
oral studies, and inhalation potency on inhalation studies. Evaluation of the dermal
carcinogenicity of PAHs was suggested, using all available data; additional dermal
carcinogenicity studies might also be useful. Some participants did not recommend direct route-

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to-route extrapolation for any of the approaches, and many participants were skeptical about the
utility and validity of the currently available pharmacokinetic modeling for mixtures.

Uncertainty associated with extrapolation of bioassay data to humans was also noted.

The lack of human toxicity data on any of the individual PAHs was a recurring concern; several
participants observed that without human data, the relevance of the animal data to human
exposure situations is questionable. One participant suggested that re-examination of the effects
of coke oven emissions in animals and humans might be useful in back-calculating a human
potency estimate for BaP, and noted that this approach has been adopted by the World Health
Organization (WHO). It was also noted that the WHO has concluded that the scientific basis for
the relative potency factor approach is lacking; currently, WHO recommends the surrogate
approach, with BaP as the surrogate indicator compound.

The use of additional indicator compounds to characterize the composition and toxicity of PAH
mixtures was recommended for all approaches. Currently, BaP is the only PAH for which
chronic exposure bioassay data are available, and thus by default, it remains the index compound
or "gold standard." Research exploring the utility and validity of using additional indicator
compounds or PAH fractions was suggested. It was noted that tumors in target organs other than
the skin have not been considered in developing relative potency estimates; a number of
published and unpublished studies have examined tumors in other organs. It was recommended
that these data be located and evaluated in conjunction with skin tumor data.

In general, participants concluded that the relative potency factor approach should be employed
only "as a last resort," when the mixture of interest was judged not to be "sufficiently similar" to
either the surrogate mixture or the specific mixtures used in developing the comparative potency
approach. A major concern was that the relative potency approach may not provide a valid
estimate of the toxic potency of the mixture as a whole and thus may not be protective of public
health. Some participants recommended that the relative potency factor approach not be used,
and that a mixtures approach be employed even if the mixture of interest has only been partially
characterized and biological activity data are scanty. Several participants noted that existing
studies comparing the composition of PAH-containing mixtures suggested that most such
mixtures were similar, irrespective of source or age. However, other participants did not think
that mixtures from different sources (e.g., combustion versus noncombustion) or with different
weathering patterns could be similar. Participants agreed that both the composition and toxicity
of PAH mixtures should be better characterized. Although there was some concern about
general similarities among mixtures, most of the discussion focused on the difficulties of
judging whether mixtures were "sufficiently similar" to each other to justify the use of a
mixtures approach.

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Action Items: Future Research and Research Needs

Throughout the discussion many recommendations were provided on information that is needed
to improve the risk assessment approaches for PAHs. Some of these comments addressed
evaluating existing data sets while others called for new research or assessments.

Recommendations for future information and research needs included: (1) EPA should convene
a panel to re-evaluate the validity and usefulness of the relative potency factor approach, using
all available data sets; (2) the oral cancer slope factor of BaP should be updated, using the data
from the recent chronic feeding study (Culp et al., 1998); (3) EPA should develop an inhalation
unit risk estimate for BaP, using available data; (4) EPA should commission a new inhalation
study, preferably with two species and two sexes per species, conducted by NTP; (5) the validity
of using BaP as the indicator compound should be re-evaluated; (6) additional carcinogenic
PAHs should be added to the current set of PAHs for which relative potency factors are derived
(EPA, 1993) (suggestions ranged from including all EPA "target" PAHs to adding only PAHs
known to be potent and removing those known to be of low potency); and (7) existing dermal
carcinogenicity studies should be evaluated to obtain information on the absorption and
distribution of PAHs and PAH-containing mixtures, and data on the systemic tumorigenicity of
exposure via this route.

Information needs are numerous and need to be prioritized. Recommendations for additional
specific testing were considered to be beyond the scope of the charge for this peer consultation.
Participants recommended that EPA convene another peer review to review the literature and to
develop a priority list of PAH compounds and PAH-containing mixtures to be tested, as well as
exposure routes for testing (particularly oral and inhalation). Additional epidemiologic data are
also needed. Existing data sets should be re-evaluated to determine the degree of
similarity/difference among complex mixtures. Other suggestions included research on: (1) the
development of markers for characterizing the degree of transformation that occurs between
source emissions and the point of exposure; (2) the development of markers for identifying
sources of mixtures of unknown origins; and (3) the use of urinary metabolites of PAH
compounds, such as 1-hydroxypyrene (a metabolite of pyrene), as biological markers of
exposure.

Particularly for the relative potency factor approach, the following testing should be prioritized:
(1) whether BaP is still the most suitable compound to test and to use as a reference standard or
whether there were other PAHs that might be more toxic/more prevalent in PAH mixtures, and
thus more appropriate for testing and use as a reference; (2) what chemicals should be presented
to NTP for testing; (3) whether recommendations for testing should be for individual PAHs or
for complex mixtures (e.g., diesel fuel, coke oven emissions, and others). In addition, the list of
relevant PAHs should be revisited — better data and a longer list of compounds are needed. It
was recommended that a group of scientists/regulators review the literature and develop a
priority list of compounds to be tested at a later date, including recommendations of route of
exposure.

It was generally agreed that data on PAHs in different media, from different sources, and from
different exposure routes are all important information needs. Media play a role in terms of PAH
bioavailability. Information on the source of the mixture influences the selection of the approach

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used for PAH assessment. Additional data on different exposure routes, particularly dermal and
dermal absorption, are needed. The National Institute for Environmental Health Sciences
(NIEHS) is examining the bioavailability of a range of compounds via different routes; for skin,
isolated human skin cultures are being used. With regard to individual PAHs, there are some
data showing that BaP and dibenz(c/,/?)anthracene are absorbed through the skin; the degree of
absorption in general depends on the molecular weight of the compound.

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1.0

INTRODUCTION

1.1 Workshop Purpose

The U.S. Environmental Protection Agency (EPA) sponsored a two-day peer consultation
workshop, inviting ten experts in polycyclic aromatic hydrocarbon (PAH) toxicology and
chemistry, and risk assessment of chemical mixtures, to examine approaches to the health
assessment of PAH mixtures. This workshop was held on October 24-25, 2001, at the Key
Bridge Marriott Hotel, in Arlington, Virginia.

Specifically, the purpose of the workshop, entitled "Peer Consultation Workshop on Approaches
to Polycyclic Aromatic Hydrocarbon (PAH) Health Assessment" was to (1) evaluate the extent
to which each of the three available approaches to PAH health risk assessment is supported by
the current scientific literature and (2) assess how well each approach addresses the range of
exposure situations and monitoring data encompassed by EPA program offices. The expert
opinions and recommendations emanating from this workshop will be considered by EPA in the
development of an appropriate and scientifically defensible health assessment procedure for
PAH mixtures. The workshop focused on the extensive carcinogenicity literature for PAHs, as
information needed to support the development of a mixtures approach for assessing the
noncancer effects of PAHs is limited or lacking.

1.2 Workshop Participants

The workshop was sponsored by EPA's National Center for Environmental Assessment (NCEA),
Office of Research and Development. Versar, Inc., an EPA contractor, provided logistical
support for the workshop. Ten experts were invited to present their views and recommendations.
Dr. Joe Mauderly served as chairperson for the two-day meeting. During the first day of the
workshop, EPA scientists presented overviews of PAH risk assessment practices in two program
offices, Office of Air and Radiation (OAR) and Office of Solid Waste and Emergency Response
(OSWER), and summaries of the three available approaches for assessment of PAH mixtures.
Discussion followed each of the presentations. During the second day, Dr. Mauderly presented a
summary of the major themes of discussion from the previous day and guided the discussion that
followed. A list of the ten participants can be found in Appendix A. The meeting was attended
by approximately 30 observers, who are listed in Appendix B. The meeting agenda is shown in
Appendix C.

The remainder of this workshop report includes summaries of the opening presentations by EPA
scientists (Section 2) and summaries of the major recommendations and conclusions provided by
the experts (Section 3). Section 4 provides more detailed proceedings and Section 5 presents
brief summaries of comments from observers. Section 6 summarizes recommendations from the
participants for future research and information needs. The appendices contain materials handed
out at the meeting.

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2.0

SUMMARY OF OPENING REMARKS AND PRESENTATIONS

Dr. Mauderly introduced the EPA presenters who included: (1) two scientists from EPA program
offices that have regulatory mandates requiring risk assessments for PAHs; and (2) four
scientists from EPA's ORD who are leading this effort to develop PAH health risk assessment
approaches. Slides used in these presentations are presented in Appendix D.

2.1	Welcome: Introduction and Background

Susan Rieth, ORD, Chair of the PAH Workshop Steering Committee, provided a background
introduction on the Integrated Risk Information System (IRIS) Program and the purpose of the
workshop. The IRIS Program develops EPA consensus scientific positions on potential human
health effects that may result from chronic exposure to chemical substances found in the
environment. Currently, there are health assessments for 15 non-methylated PAHs with 3 or
more rings that are on EPA's Priority Pollutant List, and assessments for 3 PAH-containing
mixtures: coke oven emissions, diesel engine emissions, and creosote. EPA recognizes,
however, that the current scope of PAH assessments is insufficient, given the complexity of PAH
mixtures. Although a relative potency factor (RPF) approach has been used to assess the
carcinogenicity of 7 PAHs classified as probable human carcinogens, this process has not
undergone consensus review. Three approaches, including the RPF approach, have been
employed by government and nongovernment agencies and by investigators to evaluate the
carcinogenic potency of PAHs. A discussion document, describing the three available
approaches, was prepared by EPA and distributed to the participants in advance of the meeting
(Appendix E). EPA has also published recent supplementary guidance for conducting health risk
assessments for chemical mixtures.

The experts were asked to provide: (1) input to EPA on the extent to which each approach is
supported by current scientific literature, and on the applicability of the available approaches to
different exposure situations of interest to EPA; (2) recommendations for revising existing
approaches or developing new approaches consistent with the toxicology literature; and (3) ideas
for analyses and additional research that might be undertaken by EPA to resolve some of the
more problematic issues associated with the current approaches to PAH risk assessment.

2.2	Overview of PAH Risk Assessment Practices in EPA Program Offices
2.2.1 Office of Air and Radiation (OAR)

Dr. Roy Smith, OAR, briefly discussed how OAR assesses PAH risks. The statutory basis for
PAH assessment is the Clean Air Act of 1990, which identifies 189 hazardous air pollutants
(HAPs), including 19 categories or groups of chemicals, one of which is a category for
particulate organic matter (POM), defined by Congress as consisting of organic compounds with
"two or more benzene rings, and a boiling point greater than 100° C " PAH compounds fall into
the POM category and, therefore, are considered to be HAPs. The assessment of POM was
discussed in the context of two OAR programs: (1) the national-scale assessment, which is
intended to guide the air toxics programs in prioritizing HAPs and emission sources, provide
baseline data for assessing progress, and assist in scoping more refined assessments; and (2) the
residual risk assessment (local scale), which evaluates the health risks remaining after imposition

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of control technologies. The most recent national scale assessment considered only inhalation
exposure, whereas the residual risk assessments evaluate both oral and inhalation exposures, as
appropriate.

The national-scale assessment activity begins with the national emissions inventory for
individual sources of POM and uses dispersion modeling on a census tract level to estimate
ambient air concentrations. Human exposures are subsequently modeled and dose-response
assessment and cancer risk characterization conducted. These analyses identify those pollutants
(and sources) that are driving excess lifetime cancer risks. The residual risk assessment program
uses the best available emissions data for PAH sources of interest, speciated wherever possible.
Ambient air concentrations are estimated using dispersion models, and as relevant, other media
concentrations are estimated using multi-media models. PAH oral and inhalation unit risk
estimates for cancer and noncancer toxicity endpoints are used to assess dose-response, and
estimated cancer and noncancer risks are aggregated.

Dr. Smith noted that the vast majority of POM emission estimates are engineering estimates, and
for PAHs, there is currently no "reality-check" (i.e., examining the correlation between modeled
and measured exposure data). Speciation data for individual emissions sources are currently
very limited. PAH assessments are conducted by summing the cancer risk estimates developed
for individual compounds. Both OAR programs characterize excess risks from inhalation
exposure; however, EPA has not yet come to a consensus on the derivation of an inhalation unit
risk estimate for quantitative dose-response cancer assessment of PAH mixtures in general or of
an index compound, such as BaP. OAR uses the inhalation unit risk for BaP developed by
California Environmental Protection Agency (Cal EPA), as a default (Collins et al., 1998), and
applies the RPF approach to estimate PAH risks.

In response to a question by Dr. Mauderly, Dr. Smith stated that from OAR's perspective, it
would be most useful if the participants would recommend to EPA that a consensus inhalation
unit risk estimate for PAHs be derived. It would also be helpful if the participants could suggest
refinements to approaches to PAH assessment that are more technologically and quantitatively
advanced than those now in use, so that: (1) the approaches to PAH assessment can be extended
to other compounds, including heterocyclic POMs; and (2) a more convincing argument for
measuring and speciating additional PAHs at their sources can be made.

2.2.2 Office of Solid Waste and Emergency Response (OSWER)

Dr. Lee Hofmann, OSWER, briefly discussed how OSWER currently handles PAH risk
assessment. The statutory bases for regulating PAHs are the "Superfund" and hazardous waste
legislation (i.e., CERCLA and RCRA); in general, emphasis is on site-specific risk assessments
for hazardous waste sites including incinerators and other combustion facilities. PAH risk
assessments focus on the seven PAHs classified as probable human carcinogens, using the
relative potency factor approach, as outlined in EPA's 1993 provisional guidance (EPA, 1993).
PAHs contribute significantly to calculated human cancer risks at uncontrolled Superfund sites:
in a ranking of the 50 major compounds contributing to excess lifetime cancer risk, BaP,
benzo(A)fluoranthene, and benz(a)anthracene ranked 7th, 10th, and 11th, respectively.

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In response to a question by Dr. Mauderly, Dr. Hofmann stated that from OSWER's perspective,
it would be most useful for the participants to recommend approaches to PAH risk assessment
that OSWER can use on a site-specific basis, which would include guidance for evaluating the
most important PAHs given the current state-of-the science, guidance for dealing with PAH
mixtures, and recommendation of methods to address assessment of risks from dermal exposure.

2.3 Background on Current Approaches to PAH Health Risk Assessment

EPA scientists provided background summaries on three available approaches to PAH health
risk assessment: (1) the surrogate approach; (2) the comparative potency approach; and (3) the
relative potency factor approach.

2.3.1 Surrogate Approach

Dr. Gary Foureman presented an overview of the surrogate approach. This approach assumes
that an established mixture whose chemical content and carcinogenic potency are reasonably
well known from animal or human studies can be used to assess the excess lifetime cancer risks
of a new mixture of interest having limited animal or human data. The character and content of
the established mixture is employed as a "surrogate" for the character and content of the new
mixture of interest. The underlying assumption of this approach is that the surrogate mixture is
"sufficiently similar" to the mixture of interest. Sufficiently similar mixtures may be mixtures
that are similar on the basis of: (1) the presence of specific potent compounds (e.g., BaP); (2) the
proportions or ratios of certain key PAHs; (3) the presence/absence of other contributory
components (e.g., nitro- or alkyl-PAHs); (4) source; and/or (5) mode of toxic action. Other
considerations in characterizing "sufficient similarity" include the nature of the monitoring and
toxicologic data bases, such as whether components of the PAH surrogate mixture are monitored
in environmental samples and whether components are carcinogenic, and the nature of
toxicologic interactions among components.

Dr. Foureman recognized that the major issue in the use of this approach is the definition of
"sufficiently similar." An informed scientific judgment must be made on the relevancy of the
PAH surrogate mixture to the mixture of interest. Various criteria have been developed for
evaluating the similarity of mixtures. For example, Dr. Foureman and his colleagues have
utilized the criteria described in the previous paragraph to suggest that coal tar pitch (CTP) is an
adequate and "sufficiently similar" mixture that could be used as a surrogate for other PAH
"mixtures of interest". CTP has been analyzed to identify both PAHs and other chemical
components that might be contributing to its toxicity. CTP contains the PAHs of regulatory
concern that are routinely monitored and detected in environmental samples. Some exposure
data were presented which gave support to the assumption that all PAH mixtures are similar to
CTP with respect to the PAHs present and the relative mass ratios of one PAH to another.
Further, CTP has been tested in chronic animal studies and its toxicity, including carcinogenicity
and dose-response has been characterized. If one assumes proportionality in PAH composition
between CTP and the mixture of interest, one can also assume proportionality in the health risks
associated with exposure to any "mixture of interest" as long as it is judged to be "sufficiently
similar." If, however, the mixture of interest is judged not to meet the criteria for being
"sufficiently similar" to the surrogate, then the risk analysis would default to the relative potency
factor approach.

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In the case study presented, a risk was calculated from a hypothetical "mixture of concern" based
on a comparison to the surrogate CTP. The hypothetical "mixture of concern" consisted only of
measured air levels of BaP and chrysene. As a first step, the BaP/chrysene ratio in the
hypothetical mixture was compared with that of the surrogate CTP, to judge whether the mixture
of concern could be considered to be sufficiently similar to CTP. The ratios were quite different:
1.2 / 5 in the mixture of concern but only 1 / 0.8 in CTP. Based on these differences, a judgment
could be made that the mixture of concern was not "sufficiently similar" to the surrogate CTP
either because BaP was too low or chrysene was too high. However, based on other additional
considerations, the decision was made that the mixture of concern could be prudently assumed to
be a dilution of CTP and that a risk calculation could be made. These considerations included
that (1) BaP is much more potent than chrysene and reliable risk estimates could be made based
upon the amount of BaP present in the surrogate mixture, (2) actual measured BaP concentration
should be used (i.e., the amount of BaP should not be extrapolated), and (3) the risk estimate
resulting from the assumption that the hypothetical mixture of concern was a dilution of CTP is
conservative (i.e., greater than it probably is). Calculation of the risk then proceeded using a
simple proportional procedure based on the amount of BaP in CTP.

2.3.2 Comparative Potency Approach

Dr. Stephen Nesnow presented an overview of the comparative potency approach to assessment
of PAH cancer risks from complex mixtures. This approach was initially developed by EPA to
evaluate the adverse health effects of diesel fuels in the 1980's, when it was assumed that the
entire automobile fleet would eventually be dieselized and that there would be widespread
human exposure to diesel emissions. Because human epidemiologic data are not available for
new combustion technologies, and lifetime animal carcinogenicity studies are both costly and
time-consuming, EPA explored a comparative potency method for predicting human risk based
on short-term bioassay data.

The underlying assumption of the comparative potency method is that similar mixtures in a set
(e.g., combustion mixtures) act in a similar manner toxicologically, and that the relative potency
of two such mixtures in an in vivo or in vitro bioassay is directly proportional to the relative
potency in humans, as follows:

Human cancer potency ,	= k x Bioassay potency ,

Human cancer potency 2	Bioassay potency mixturc 2

For a mixture of interest of unknown potency considered to be a member of this group of similar
mixtures, human cancer potency can be estimated from bioassay data by rearranging the above
equation:

Human cancer potency x = Bioassay potency mixturc x x k

This assumption was examined for three complex organic emission products (from cigarette
smoke, coke oven emissions, and roofing tar) that had previously been shown to be associated
with the induction of respiratory cancer in exposed human populations. Emission products were
tested in various in vitro bioassay systems and in mouse skin tumor initiation assays with several
strains of mice. For these three emission products, data from the Senear mouse skin tumor

5

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initiation assay was most highly correlated with unit risk estimates for lung cancer. In the
Senear mouse skin tumor initiation assay, mice were given a single treatment with the test agent
applied to shaved skin; one week later, they were exposed to daily applications of a potent
promoting agent (phorbol ester). Animals were scored for tumors every week; most had
developed skin papillomas by weeks 20-26 and skin carcinomas were observed by 60 weeks.
The different combustion mixtures were ranked by tumor multiplicity (number of papillomas per
mouse per 1 mg organics) and tumorigenic dose25 (TD25 = the dose that induces a 25% increased
incidence of tumors relative to background), and responses were normalized to coke oven
emissions. The potency rankings coincided for both tumorigenic end points (coke oven
emissions > roofing tar > cigarette smoke). Inhalation unit risk estimates derived from
occupational epidemiology studies on coke oven emissions, roofing tar, and cigarette smoke
were used to rank these three mixtures, again normalizing to coke oven emissions. These
rankings also coincided with the animal bioassay data.

For the combustion mixtures data set, the k factors varied by a factor of 16 (ranging from 0.25 to
4.0) depending on which mixture pairs were used to determine k (e.g., coke oven emissions
versus roofing tar; roofing tar versus cigarette smoke). The human cancer potency for diesel
emissions was determined by using cancer data from a rat inhalation study and multiplying it by
k. Using this approach, the relative potency of diesel emissions was less than roofing tar but
more than cigarette smoke.

The strength of this approach is based on the concept that the potency of a PAH-containing
mixture can be estimated without having to either identify or quantify individual PAH
components. To use this approach, a simple and low-cost animal assay would be performed with
the mixture of interest and the results extrapolated to humans, using a scaling factor determined
from a set of similar mixtures. However, there must be sufficient evidence to determine that the
mixture of interest is: (1) a potential human carcinogen, and (2) sufficiently similar to the set of
mixtures used to develop the scaling factors.

2.3.3 Relative Potency Factor Approach

Dr. Lynn Flowers presented an overview of the relative potency approach for the assessment of
PAH cancer risks from complex mixtures. One application of this approach (EPA, 1993) is used
for health risk assessments at Superfund and RCRA sites within OSWER, where the sources of
mixtures of interest are usually abandoned hazardous waste sites, such as coke ovens,
manufactured gas plants, and steel mills, or active industrial chemical facilities. Many of these
sites have existed for decades and the PAH contamination has been altered over time by
numerous aging/weathering processes, including environmental fate and transport. The relative
potency factor approach provides provisional/interim guidance (EPA, 1993) for assessment of
PAH risks at these sites, as well as for other program purposes. This approach is based on the
toxicity of select individual components of mixtures, and assumes additivity. Thus, it avoids the
issues pertaining to complex differences among PAH mixtures and is considered to represent a
compromise approach. However, the toxicity of other key mixture components and interactive
effects are not considered. Excess lifetime risk is estimated by assigning relative potency values
to a set of individual PAHs which are known to play a role in toxicity and for which toxicity data
are available.

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BaP is utilized as the standard or "index" PAH with the highest ranking, and is assigned a
relative potency value of 1.0. The "estimated order of potential potency (EOPP)" of 6 additional
carcinogenic PAHs (i.e., those classified as probable human carcinogens) is determined relative
to BaP. The EOPPs are based on data from complete carcinogenesis assays using mouse skin,
assumes additivity of PAH responses, and is considered to be appropriate for oral exposures
only. For each PAH, the oral cancer slope factor of BaP is multiplied by the relative potency
factor to yield a relative estimate of potency. The estimated risks associated with individual
PAHs are summed to yield a cumulative PAH risk estimate. Cal EPA, Ontario Ministry of the
Environment (OMOE), and various program and regional offices within EPA also utilize this
approach for inhalation exposures.

The oral cancer slope factor for BaP is based on a composite analysis of the results from two
chronic dietary exposure studies in rats and mice which produced forestomach papillomas and
tumors.

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3.0

SUMMARY OF KEY COMMENTS AND RECOMMENDATIONS

A summary of the key comments and recommendations over the course of the two-day workshop
is presented in this section. A more detailed discussion is presented in Section 4.0.

3.1 Surrogate Approach

The surrogate approach is based on mixtures in which the PAH content of unknown "mixtures
of interest" are considered to be dilutions of a surrogate PAH-mixture. The approach assumes
that the risks due to an unknown PAH mixture vary proportionately to the risks from a surrogate
mixture. The major advantage to the surrogate approach is that it is based upon a whole mixture
and that the composition and toxicity of the surrogate mixture as a whole is known. The use of
toxicity data from a whole mixture permits consideration of toxicological interactions, which
toxicity data derived from single components are unable to assess. Consideration of interactions
reduces the uncertainty about such interactions. Several participants stated that the surrogate
approach thus exhibits notably less uncertainty than do the other approaches, and is also more
conservative; therefore, it is the preferred approach. It was observed that data from OMOE
suggest that the composition of most mixtures, irrespective of sources, environmental media, or
weathering, is reasonably similar. It was recommended that further analysis be conducted on a
range of complex mixtures to determine composition and the degree of similarity/difference
among mixtures.

The principal issue associated with this approach is the reliance on the finding of "sufficient
similarity" between the mixture of interest and the surrogate mixture. Further, "sufficient
similarity" implies similarity in biological activity, and only a limited number of complex
mixtures have been evaluated for toxicity in either animals or humans. Some participants
considered this approach to be limited by the criteria used for selection of a surrogate or
reference mixture. Other participants recognized that this determination may be a subjective
judgement. One participant observed that the principal limitation of this approach, in its present
form, was that it only accounted for the PAH fraction of a complex mixture (specifically the
unsubstituted PAH fraction) and that the toxicity from other components of the mixture
(including nitro and other substituted PAHs) was not addressed. It was also noted that, in the
example given for this approach, the animal bioassay data were only for inhalation exposure, and
that the approach might not be currently useful (at least without further refinements) for
assessments in which ingestion and dermal routes of exposure are important. Some participants
recommended that other reference mixtures be identified and characterized, and that the use of
additional indicator compounds for estimation of potency be explored. Suggestions for other
indicator compounds included: (1) the group of 7 PAHs classified as probable human
carcinogens and currently utilized in the relative potency factor approach; (2) the 4- to 7-ring
PAH fraction; (3) total organic carbon (TOC); and (4) total PAH mass. It was also suggested
that the data from the diesel emissions study might be utilized to identify additional surrogate
indicator compounds and evaluate their usefulness for characterizing whole mixtures.

3.2 Comparative Potency Approach

The comparative potency approach is another whole mixtures approach, in which human and
animal toxicity data for a group of mixtures considered to be "sufficiently similar" are used to

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derive a scaling factor which can be applied to other mixtures to estimate human cancer potency
from animal bioassay data. A major advantage to this approach is that the toxicity for the whole
mixture is characterized, whether or not the composition of the mixture is known. The key
assumption underlying this approach is that the ratio between the potency of a mixture in an
animal bioassay and the human cancer risk is constant for different PAH-containing mixtures.
The mouse skin tumor initiation assay has been considered to be a reasonably good predictor of
the relative potency of carcinogenic mixtures, assuming that mechanisms of tumorigenic action
are similar in both humans and animals. Major issues associated with this approach include: (1)
it cannot be used with mixtures from multiple or unknown sources; (2) there is considerable
uncertainty about the reliability and validity of the lung cancer epidemiology studies which are
available to derive scaling factors, because of the confounding effects of smoking; and (3) this
approach is currently based on inhalation exposure data and might only be applicable to the
inhalation route because no human oral exposure studies are available. The approach also
assumes that the composition and toxicity of different samples from the same source category
(e.g., diesel emissions) are similar; however, testing of diesel emissions suggests this assumption
may not be valid. Most participants were skeptical about the use of PBPK models for route-to-
route extrapolation because of the difficulty of characterizing the toxicokinetics of a complex
mixture containing numerous compounds. Route-to-route extrapolation of data was not
recommended based on the current state-of-the science. Although the mouse skin tumor
initiation assay is a good predictor of the potency ranking of complex mixtures with regard to
human lung cancer, the relative potency ranking needs to be demonstrated for other routes of
exposure. Other assays should be considered.

3.3 Relative Potency Factor Approach

The relative potency factor approach is a component approach, in which the carcinogenic
potencies of selected PAHs relative to an index compound (e.g., BaP) are determined, and
individual PAH risks are summed to yield a cancer risk estimate for the whole mixture. Current
EPA provisional guidance for assessing PAH risks (EPA, 1993) utilized this approach. BaP is
the recommended standard. The key assumptions underlying the use of this approach are that (1)
individual PAH risks are additive and (2) the sum of the risks of selected PAHs adequately
characterizes the risk for the entire PAH component of the mixture. The advantage of this
approach is that it is practical for exposure situations in which the source and the composition of
the mixture are not fully known. However, participants were in general agreement that this was
the least scientifically-defensible approach, and that any approach that utilizes the toxicity of a
mixture as a whole is preferable to the use of the relative potency factor approach.

The major issues associated with this approach are that (1) it is not based on a reference PAH
mixture with known toxicity (animal or human), (2) there are no human toxicity data on any of
the individual PAHs, and (3) the assumption of additivity of individual PAH toxicity may not be
valid. Other issues associated with the current provisional guidance (EPA, 1993) include: (1) the
use of too few, and possibly the wrong, PAHs, (2) the reliance on BaP as the index compound
(several studies have shown that BaP as an indicator compound may not accurately predict the
carcinogenic potency of whole mixture, and may underestimate potency); (3) the lack of
consideration of interactions among PAHs, and between PAHs and other mixture components
such as metals; and (4) the applicability of this approach to oral exposure only. There were also
questions raised regarding the adequacy of mouse skin tumor initiation studies for developing

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relative potency factors. It was recommended that the database of in vitro carcinogenicity
studies be evaluated for potential use in developing RPFs. It was recommended that, ideally,
these factors be derived from low-dose chronic exposure studies.

3.4 Cross-Cutting Issues

While much of the experts' discussion focused on the three approaches, there were many issues
raised that pertained to all three methods and the challenges facing PAH risk assessment in
general. It was noted frequently that most data on the carcinogenicity of PAHs comes from
mouse skin tumor initiation studies. Some participants recommended that chronic exposure
studies be conducted on key PAHs and PAH mixtures, and that oral potency should be based on
oral studies, and inhalation potency on inhalation studies. Evaluation of the dermal
carcinogenicity of PAHs was suggested, using all available data; additional dermal
carcinogenicity studies might also be useful. Some participants did not recommend direct route-
to-route extrapolation for any of the approaches, and many participants were skeptical about the
utility and validity of the currently available pharmacokinetic modeling for mixtures.

Uncertainty associated with extrapolation of bioassay data to humans was also noted.

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weathering patterns could be similar. Participants agreed that both the composition and toxicity
of PAH mixtures should be better characterized. Although there was some concern about
general similarities among mixtures, most of the discussion focused on the difficulties of judging
whether mixtures were "sufficiently similar" to each other to justify the use of a mixtures
approach.

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4.0

DETAILED PRESENTATION OF INDIVIDUAL DISCUSSION TOPICS

This section provides detailed discussion among the participants on the three available
approaches. Each approach is presented individually, noting the strengths and weaknesses of the
approach as well as other issues raised by the participants.

4.1 Surrogate Approach

The participants provided comments and recommendations on issues relevant to the use of the
surrogate approach. The major issues raised were: (1) strengths of the approach, (2) limitations
of the approach, (3) defining sufficiently similar mixtures, (4) addition of reference mixtures, (5)
modifications to the surrogate approach, (6) BaP as the indicator, (7) interactions/additivity, and
(8) route-to-route extrapolation.

Strengths of the Surrogate Approach

Dr. Nesnow stated that in his judgment, the surrogate approach is an improvement over the
relative potency factor approach, mainly because it utilizes inhalation bioassay data on the
reference mixture as a whole. However, this approach is limited to the inhalation route of
exposure and to mixtures for which human inhalation data are available.

Limitations of the Surrogate Approach

Dr. Nesnow noted that one weakness of this approach is the use of a single PAH (e.g., BaP) as
the indicator compound, and the assumption that BaP tracks the activity of the PAH component
of the mixture. Dr. Nesnow's studies have demonstrated that the activity of BaP in a mixture
does not explain the activity of the mixture as a whole. In mouse-skin tumor initiation assays,
Dr. Nesnow evaluated the dose-response for BaP as an indicator of the carcinogenic potency of
combustion mixtures. The results showed that BaP in these combustion mixtures did not
adequately characterize the potency of these whole mixtures.

Defining Sufficiently Similar Mixtures

A major issue concerning the use of the surrogate approach involves a judgment of "sufficient
similarity" between the surrogate mixture and the mixture of interest. One issue concerns the
chemical characterization of the mixture found in environmental media, which may differ from
the original source mixture. Dr. DiGiovanni added that the ratio of individual constituent
concentrations in the mixture was much more important than the concentration of specific
compounds. Dr. Donnelly also questioned whether weathering (e.g., microbial oxidation) and
transport would not greatly alter the downstream components of environmental mixtures,
especially those distant from sources. If this occurs, the ratios/concentrations of PAHs in a
mixture at the source may differ from those at the point of exposure, and thus characterization of
the mixture at its source might not adequately represent the composition of the environmental
mixture. Dr. Goldstein noted that in his judgment, a definition of sufficient similarity would be
based on legal, not scientific, considerations. Dr. Nesnow disagreed, noting that sufficient
similarity is based on a scientific weight-of-evidence approach for toxicologic similarity as well
as similarity of chemical composition.

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A concern of some participants was the lack of good epidemiologic data on mixtures, showing
similarity in biological activity across different mixtures. It was noted that a designation of
"sufficiently similar" includes similarity in toxicity or health outcome, in addition to similarity in
composition. Dr. DiGiovanni commented that the range of biological activity is broad with
animal data and that it would be even broader with epidemiologic data; he suggested that if the
partial composition of a mixture of interest is known, it would be useful to use several surrogate
mixtures. A number of participants agreed that there was no good substitute for testing the
biological activity of whole mixtures but that such testing was not usually practical in terms of
time and resources. However, Dr. Goldstein noted that the cost estimates for cleaning up
hazardous waste sites ranged in the trillions of dollars. Based on these estimates, it would be
worthwhile to spend some resources on refining the surrogate method, and other appropriate
methods for assessing the risks of complex environmental mixtures.

Dr. Muller noted that he and his colleagues at OMOE have evaluated the use of the surrogate
approach and concluded that the complex mixtures containing PAHs cannot be assessed as a
whole. Instead, Dr. Muller defined a PAH-rich fraction as consisting only of unsubstituted
PAHs. Mixtures were judged to be similar, if at the same concentration of BaP, the risk
estimated from the predicted composition of the mixture and that estimated from the actual
composition of the mixture (for the unsubstituted PAH fraction) did not differ by more than one
order of magnitude. Dr. Muller noted that this standard forjudging the similarity between
mixtures is appropriate, because risk assessment is always associated with a degree of
uncertainty. In general, few dose-response assessments are associated with uncertainty of less
than one order of magnitude, and thus potency predictions within one order of magnitude are
considered to be acceptable. In the OMOE evaluation, the differences were much smaller,
suggesting that the surrogate approach is suitable for assessing the potency of the unsubstituted
PAH-rich fraction of mixtures. Risks from other components of complex mixtures need to be
estimated separately.

Addition of Reference Mixtures

Dr. Foureman noted that the surrogate method is currently tied to one specific mixture (i.e.,
CTP) and an animal bioassay assessing the inhalation toxicity of that mixture. One issue raised
with the current application of the surrogate approach is the use of a single reference mixture,
considered by some experts to be a weakness of this approach. It was suggested that the use of
several reference mixtures and a range of reference indicators would significantly improve the
approach. Additional mixtures that might be useful as reference mixtures include coke oven
emissions, creosote, and Chinese smoky coal. Dr. Foureman asked for guidance from the
participants as to how to include other mixtures in the surrogate approach, based on a judgment
of "sufficiently similar." One suggestion was to examine several different mixtures and evaluate
the relationship between BaP activity and that of the mixture as whole, taking several samples of
each mixture. This analysis would determine whether differences in the risks between two or
more complex mixtures were proportional to differences in BaP concentrations in each of the
mixtures. Dr. Muller noted that the unsubstituted PAH fractions for complex mixtures are
sufficiently similar for dose-response purposes. The experts discussed the possibility of
developing a better surrogate method by using more PAH indicators and more reference
mixtures.

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Two alternate approaches to the use of several reference mixtures were discussed. Dr. Mauderly
noted that if a number of different reference mixtures were available, the one most similar to the
mixture of interest could be selected as a surrogate. Dr. Nesnow stated that it would be more
appropriate to estimate a range of potencies for the mixture of interest, using all reference
mixtures; in his judgment, there was too much uncertainty associated with characterizing the
similarities and differences of complex mixtures to be able to select the "most similar" reference
mixture.

Modifications to the Surrogate Approach

Dr. Mauderly questioned whether it was reasonable to merge the surrogate and RPF approaches
and use a group of PAHs as indicators of potency. Dr. Wise noted that the validity of this
approach (i.e., the use of multiple PAH indicators) depended on the relative proportion of PAHs
in the mixture. He stated that PAHs account for approximately 20% of the total mass of coal tar,
with the remaining 80% usually not being characterized. Therefore, the more complex the
mixture (in terms of presence of other compounds), the less useful this approach. However, this
is true for all mixtures and all approaches to PAH risk assessment. Dr. Goldstein noted that
there are data on refinery streams which demonstrate that the best correlation with potency
occurs with the use of 4- to 7-ring PAHs as indicators; BaP does not correlate as well with
potency as this group of PAHs. According to Dr. Wise, to measure 4- to 7-ring PAHs one must
measure each of the relevant constituent compounds separately; it is not possible to measure this
group as a whole.

Dr. Goldstein noted that the majority of PAH toxicity data come from mouse skin-painting
studies. To obtain better toxicity data, other biological data should be evaluated, including mode
of action information and data from other exposure routes.

To account for variability, Dr. Nesnow suggested that a range of indicator compounds be used;
the risk of each indicator could be calculated, yielding a range of risks from which the upper and
lower bounds could be estimated. Dr. Goldstein added that toxicity data should be characterized
similarly; that is, a range of potency estimates should be calculated rather than using a single
point estimate for the dose-response assessment of biological data.

BaP as the Indicator

Dr. DiGiovanni noted that although BaP may be useful as an indicator, it may not give a good
representation of the mixture potency. Some participants stated that the use of more than one
indicator compound would be useful. Several participants contemplated what additional
indicator chemicals might be proposed. In comments submitted following the workshop, Dr.
Muller noted that he did not share the view that multiple indicators would improve application of
the surrogate approach. In his experience, using multiple unsubstituted PAHs in the 4- to 6-ring
range would yield results similar to those with BaP and, furthermore, would make the
assessment more complex. Drs. Nesnow and Baird suggested looking at total organic carbon
(TOC), or total PAH mass for characterization of "sufficiently similar" in terms of composition;
in their judgment, it was not necessary to use an indicator that has been tested in animal studies.
Mixtures should be characterized as "sufficiently similar" not only in terms of PAHs but also in
terms of other constituents such as nitroaromatics or phenols. It was suggested that the mixture

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of interest, as well as the reference mixture(s), should be better characterized. Although the
surrogate approach addresses the PAH fraction, the risk for other mixture constituents (e.g.,
metals, other organic compounds) must be estimated separately, and the presence of other non-
PAH constituents may affect the potency of PAHs. Thus, differences in composition may alter
mixture toxicity; however, the extent of these interactions is not known. Drs. Nesnow and
Albert suggested that the data set for diesel emissions might be further evaluated to explore
additional surrogate indicators and to assess whether these indicators would be useful.

Inter actions/Additivity

A discussion followed of interactions among PAH compounds in a mixture. There was concern
among some participants that the use of a single indicator compound, or even several, would not
adequately characterize the potency of the whole mixture because of interactions. Dr. Baird
noted that small amounts of some PAHs (e.g., benz(a)anthracene) may greatly affect the
carcinogenicity of other PAHs (e.g., BaP); benz(a)anthracene appears to be an activating
compound even though its relative potency is considered to be low. Dr. Thorslund added that
PAH interactions in mixtures are concentration-dependent, and thus low environmental levels of
PAHs may not exhibit the same kind of interactions observed at higher concentrations in the
laboratory. Dr. Nesnow stated that elevated concentrations of pyrene in a complex mixture
appear to obliterate the ability of BaP to induce tumor-forming cell masses and that pyrene is
usually present at high levels in environmental samples.

Data evaluating the assumption of additivity of biological activity among PAHs were presented
by Dr. Nesnow, who has studied interactions among 5 key PAHs in strain A/J mice. Predicted
responses (lung tumors following a single intraperitoneal injection), based on individual dose-
response studies, were compared with actual responses, based on mixtures containing
environmental ratios of PAHs. Dose-dependent interactions were observed with the mixtures:
more tumors occurred than predicted at low doses, and fewer tumors occurred at high doses.
However, the extent of these dose-dependent differences in additivity for the 5 PAHs was
approximately 2-fold, which is generally considered to be within acceptable bounds for a risk
assessment. However, if pyrene was added to the mixture, the tumorigenic activity of the
carcinogenic PAHs was inhibited, demonstrating the complexity of mixtures containing other
PAHs. Other compounds in a PAH-containing mixture might also modulate the carcinogenic
effects of individual compounds (e.g., in the mouse skin assay, tobacco smoke inhibits the
tumorigenic activity of BaP whereas roofing tar enhances it. Nonetheless, Dr. Muller pointed
out that the variability was, at most, within one order of magnitude, and that the interactions in
actual mixtures would likely go both ways (i.e., inhibition and enhancement). Drs. Albert and
Mauderly suggested that the literature be examined and summarized to determine the extent to
which additivity occurs, and whether the range of estimates based on summing individual dose-
response data is within acceptable limits for a regulatory risk assessment. It was noted that
genetic variability and other factors may increase the variability.

Route-to-Route Extrapolation

Route-to-route extrapolation of tumor findings in animal studies was discussed. Dr. Goldstein
noted that no lung tumors were observed in a recent two-year feeding bioassay with BaP,
although forestomach tumors were observed at the site of contact. However, DNA adducts in the

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lung were observed., suggesting that orally-ingested BaP reaches the lungs. Dr. Nesnow stated
recent work has questioned the sole use of stable adducts to define dose-response curves; the
formation of stable adducts are not necessary for tumor formation, as there are other processes or
mechanisms which can be involved in tumorigenesis (e.g., formation of reactive oxygen
species).

4.2 Comparative Potency Approach

The major issues raised during the discussion of the comparative potency approach were the
following: (1) strengths of the approach, (2) limitations of the approach, (3) additional reference
mixtures, (4) human relevance, and (5) route-to-route extrapolation.

Strengths of the Comparative Potency Approach

This approach is based on the availability of toxicity data for a group of similar mixtures. The
advantage to this approach is that the toxicity for the whole mixture has been characterized,
whether or not the composition of the mixture is known. Dr. DiGiovanni noted that, in his
judgment, the comparative potency approach appeared to be the most accurate and had the most
confidence as compared with the other approaches. Several participants agreed.

Dr. Muller noted that the assumption of sufficient similarity applied to both the surrogate
approach and the comparative potency approach. He and his colleagues have looked at both
models and have shown that there is a good relationship between the two: using an intact animal
model, the relative potency of mixtures are similar for both approaches.

Limitations of the Comparative Potency Approach

The comparative potency approach was judged by some experts to have limited applicability.
Dr. Mauderly noted that there were two types of uncertainties in this approach: (1) the relevance
of the animal bioassay; and (2) the quality of the epidemiologic data. Dr. Donnelly observed that
the assessment of the carcinogenic potency of complex mixtures in the range of environmentally-
relevant concentrations is difficult because animal carcinogenicity experiments are conducted
with very high concentrations, and dose-response information in the range of human exposures is
usually not available. He questioned whether the comparative potency approach has validity
without environmentally-relevant dose-response data.

Dr. Muller commented that he thought the comparative potency approach was limited in its
application to environmental mixtures. For example, in Hamilton, Ontario, mixtures to which
humans are exposed are complex and come from a variety of sources: steel industry coke ovens,
diesel/gasoline engines, home heating (wood and oil), and others. In landfills, environmental
mixtures are atypical and also come from a variety of sources. Each of these mixtures are likely
to have different characteristics and one would have to do dispersal modeling and fingerprinting
to identify sources. The comparative potency approach would not be applicable to any of these
mixtures. Dr. Nesnow agreed that the comparative potency approach was not useful for sites
with contaminants from a lot of different sources, and suggested instead that this approach might
be utilized to assess relative risk reduction resulting from implementation of improved
technology controls.

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Dr. Muller noted that the biggest problem with the comparative potency approach was practical:
it cannot handle mixtures from multiple or unknown sources. He also noted that an implicit
assumption of the approach, that mixtures from a source category are "sufficiently similar," may
not always hold. Data from Dr. Nesnow's laboratory for diesel exhaust showed that samples
collected from different diesel engines had different biological potencies and different
proportions of PAHs in the organic fractions.

Dr. Goldstein noted that this approach would be based on inhalation exposure data because no
human data are available for the oral and dermal routes of exposure. At many hazardous waste
sites, the overall risk for inhalation exposure was very small compared to the risks from
ingestion and dermal exposures. Thus, the application of the comparative potency approach was
only valid in exposure situations where the risk from inhalation drives the overall risk. For
exposure situations in which ingestion and dermal routes are important, this method would not
be appropriate. Further, the epidemiologic data for roofing tar and coke oven emissions might be
limited by the failure to address the confounding effects of cigarette smoke. Dr. Albert noted
that this approach may be limited to combustion mixtures for which the major route of exposure
is via inhalation and the relevant health outcome is lung cancer. For internal consistency, the
results from whatever animal bioassay is used should give the same relative potencies for the
standard mixtures (i.e., coke oven, roofing tar, cigarette smoke) as the epidemiologic data. Dr.
Albert suggested that the toxicologic data base should be updated and that this approach be re-
evaluated using data from the most recent coke oven emissions study.

Additional Reference Mixtures

Dr. Mauderly questioned how data from other complex mixtures would be handled using this
approach and whether the current standard mixtures were adequate for evaluating the range of
complex mixtures occurring in the environment. He suggested that a new set of standard
mixtures might be developed, or the database on the current standard mixtures might be updated.
Dr. Nesnow agreed that more standards for different kinds of mixtures are needed, and that
rodent inhalation studies for other mixtures were available that might be useful in expanding the
list of standard mixtures.

Human Relevance

A limitation of this method is that only animal bioassay data would be available for mixtures of
interest, and thus, it would not be known whether the animal results were relevant to the health
outcome of interest in human populations. The choice of animal test is important. Dr. Nesnow
noted, however, that EPA's default procedure for regulatory risk assessment is to extrapolate
findings in animal bioassays to humans; therefore, data from epidemiologic studies are not
necessary to estimate human risks from animal studies.

Dr. Mauderly asked whether the mouse skin-painting bioassay was still considered to be the
"gold standard" for comparing findings across mixtures This assay could provide the animal
data used for the comparative potency approach. Dr. Albert noted that a number of short-term
tests have been evaluated for their usefulness in predicting lung cancer; however, the mouse
skin-painting assay still gives the best correlation with epidemiologic data. Dr. Nesnow noted
that the Chinese hamster ovary (CHO) test gave good results but agreed that an in vivo assay

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(e.g., from mouse skin studies) was likely to be more widely accepted than in vitro testing. At
this time, there are no new genetic approaches that might be better.

Dr. Mauderly noted that the mouse skin-painting assay was not used to predict human risk
directly but was used to extrapolate risk from animals to humans, based on a scaling factor
derived from the standard mixtures for which the relationship between the results in the mouse
assay and those in human studies was known. However, an underlying assumption was that the
mechanisms of tumorigenic action were similar in both humans and animals. Dr. DiGiovanni
added that the mouse skin assay did not assess compounds that were mainly promoters; if a
mixture had a strong promoting ability, a complete carcinogenesis model might be more
appropriate. Dr. Albert noted that several investigators have postulated that promotion does not
occur at lose doses. Dr. DiGiovanni suggested that promotion might occur at low doses with
some mixtures, depending on the composition of the mixture. Thus, low-dose chronic exposure
studies were important for the assessment of the biological activity of complex mixtures, and
should be conducted for at least some mixtures. Dr. Nesnow noted that the use of the Senear
mouse model shortened the length of the experiment by 6 months, and that the ranking of
potency in low-dose chronic exposure studies and in Senear mouse skin-painting assays was the
same. Dr. Goldstein suggested that more than a single in vivo animal bioassay should be used
for developing the correlation between animal and epidemiologic studies, incorporating more
target organ systems and additional routes of exposure. A weight-of-evidence should encompass
more than one bioassay and all available data should be re-evaluated. Other participants
suggested that one assay might be sufficient, or that more than one assay might be used, if
available.

Dr. Albert questioned whether skin tumors in mice were relevant to the development of lung
tumors in humans. Dr. Nesnow replied that the relative potencies for human lung tumors were
reliably predicted on the basis of mouse skin tumor responses. The induction of lung tumors in
inhalation studies, in which animals are exposed to aerosols of organic matter, are difficult to
interpret; no tumors are induced until the lungs are overloaded with particulates. Dr. Mauderly
added that although rats exposed experimentally to high concentrations of diesel particulates for
a lifetime did develop lung tumors, organic constituents did not appear to be the causal agent
because particles without organic matter (e.g., carbon black) also induced a similar yield of lung
tumors. In this case, inhalation exposures of rats did not reflect carcinogenicity of the organic
portion of diesel soot, even at high doses. Dr. Thorslund questioned the reliability and validity
of human lung cancer studies, noting that they are all confounded by smoking status and the
length of time of smoking. Therefore, the observed lung tumor effects in epidemiology studies
were likely due to an interaction between cigarette smoke and combustion mixtures.

Discussion followed on which animal assays to use to generate data that would be useful for the
application of the comparative potency approach. A number of assays were briefly reviewed,
including the transgenic mouse model, transgenic systems using both initiating and promoting
test agents, oncogene expression profiling for classes of compounds to develop molecular
signatures for cancer-causing chemical agents, DNA damage-repair, and other genotoxicity
systems. It was generally agreed that these new models were in their infancy phase and would
not be useful for regulatory purposes for some time.

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Several participants were also skeptical about the human relevance of the results from skin-
painting tumor-initiation assays in Senear mice, stating that it was questionable to extrapolate to
humans the results from an experimental protocol developed in a sensitive mouse strain for the
purpose of "creating tumors." Dr. Nesnow noted that the tumor processes may have a lot of
similarities even though they are not the same: for example, both lung and skin tumors are
epithelial in origin. Dr. DiGiovanni noted, however, that in lieu of other data, the mouse skin-
painting assay is the best predictor of potency ranking of complex mixtures and that there are
multiple epidemiologic data sets that validate the utility of this model. Thus, the mouse skin
model has relevance for human potency ranking.

Route-to-Route Extrapolation

The issue was raised on whether this approach can be extrapolated to other routes of exposure.
Both Drs. Nesnow and Goldstein agreed that oral exposure should be investigated using oral
bioassay data. It was generally agreed that the exposure situations for which this approach
would be applicable were all those with sufficient exposure/health outcome data. Dr. Muller
noted that an issue of concern was being able to match the bioassay data with the human health
outcome of interest. Dr. Goldstein suggested that the relative potency ranking needed to be
demonstrated for other routes of exposure. Dr. Muller pointed to data from Grimmer and
colleagues who found good correlations between relative potencies in mouse skin
carcinogenicity assays and lung implantation studies for the same PAHs and PAH mixtures. Dr.
Goldstein noted that the use of only inhalation data to assess cancer risk was considered by many
investigators to be a default approach, utilized when data from other routes of exposure were
lacking.

The use of PBPK modeling for route-to-route extrapolation was discussed. Several participants
(Drs. Nesnow, DiGiovanni, Albert, Donnelly) were skeptical regarding the use of PBPK for
extrapolation of the effects of skin painting to systemic effects induced by exposure via other
routes. Skin painting causes local effects which result from topical application, and the
relevance of PBPK extrapolation was likely to be limited. Dr. Donnelly noted that skin painting
studies may overestimate the systemic toxicity, based on studies showing a higher rate of adduct
formation following dermal as compared with oral exposures. Dr. Goldstein disagreed, noting
that the distribution of adducts differed, depending on whether administration was dermal or
oral. Several participants also felt that it would be extremely difficult to get reliable PBPK data
on complex mixtures. For example, it is not clear what responses could be measured that would
be considered representative of a complex mixture with numerous constituents.

4.3 Relative Potency Factor Approach

The major issues raised during the discussion of the relative potency factor approach were the
following: (1) limitations of the approach, (2) use of the approach; (3) comparison with other
approaches; (4) adequacy of animal data sets; (5) human relevance of animal data;(6) assumption
of additivity; and (7) use of additional/other reference compounds; and (8) route-to-route
extrapolation.

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Limitations of Relative Potency Factor Approach

Overall, the major limitations of this approach are (1) the use of only 7 PAHs, expressed in terms
of BaP equivalents; and (2) assumption of additivity of effects. Drs. Nesnow and Muller agreed
that the relative potency factor approach does not adequately characterize mixtures and preferred
any approach that tests the whole mixture. In addition, too few PAHs are used and there is too
little empirical information on the mixture. Therefore, the mixture potency is likely to be
underestimated. Further, the toxicity characterization uses old data from the 1970's and mode of
action information is not examined.

Dr. Albert noted that there were discrepancies in the relative potency factor for
dibenz(c/,/?)anthracene. Some papers indicate that it should be 5.0, not 1.0, which is currently the
default RPF according to EPA's 1993 provisional guidelines. There are about 3-4 data sets from
which differing values can be derived, and considerable uncertainty exists regarding the shape of
the dose-response curve for high-to-low-dose extrapolation. Dibenz(c/,/?)anthracene appears to
be more nonlinear than BaP.

Use of Relative Potency Factor Approach

Given the major limitations of this approach, the issue was raised as to whether participants
should recommend either continued use of the relative potency factor approach or suggest that a
different approach be employed. Dr. Nesnow commented that if EPA continues to use this
approach, routine analysis should be conducted on other heterocyclic and methylated compounds
that are not currently on EPA's target compound list (TCL). Dr. Nesnow further suggested that
EPA convene a panel to re-evaluate the relative potency factor approach; a number of different
data sets should be examined and consensus reached about how to use all available data.
Otherwise, the relative potency factor approach will continue to underrepresent the potency of
complex PAH-containing mixtures.

Dr. Muller did not recommend the use of the relative potency factor approach on the basis that it
consistently underestimates the risk from the PAH fraction of the mixture. He felt that the
surrogate approach was applicable to most real world situations. Dr. Goldstein added that if the
relative potency approach were to be used, two factors needed to be considered: (1) the relevance
of the tumor outcome in animal experiments to the tumor outcome of concern in humans; and (2)
whether the potency of the indicator PAH (i.e., BaP) has been adequately characterized for the
estimation of reliable and valid relative potency factors for other PAHs in the mixture. He noted
that the oral cancer slope factor for BaP derived from a recent chronic feeding bioassay was 1.2
per mg/kg/day (Culp et al., 1998), as compared with the cancer slope factor of 7.3 per mg/kg/day
currently being used by EPA. If the more recent cancer slope factor were used, the risks
associated with all PAHs using the relative potency factor approach would change.

Dr. Albert commented that the relative potency factor approach was both usable and practical,
especially in exposure situations where the source and composition of the mixture were
unknown. The validity of this approach, however, was questioned by other participants. Dr.
DiGiovanni noted that this approach lacks biological activity data and thus is likely to
underestimate mixture potency. Dr. Nesnow noted that the carcinogenic potency of the index
PAH (BaP) is based on animal, not human, data, and agreed that the validity of these data has

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never been satisfactorily established. Several participants suggested that there were data in the
literature, as well as in reports and other documents, that might be used to re-assess the
carcinogenic potency of BaP. Dr. Muller noted that a comparative analysis of the potency of the
PAH fraction (as determined in skin painting and lung implant studies) and the potency of the
sum of the 7 individual carcinogenic PAHs showed a fairly sizable and consistent difference
between the two; the 7 PAHs underpredicted the carcinogenic potency of the PAH mixture by
greater than one order of magnitude. A comparison of the risk estimates from coke oven
emissions with the risk of the sum of the individual PAHs also yielded a difference of similar
magnitude.

It was again noted that the ratios of the individual constituent concentrations might be as
important as the absolute concentrations. Further, the presence of additional PAHs might affect
the health outcome. The problem with the relative potency factor method, according to Dr.
DiGiovanni, is that this approach is not based on a reference material with known biologic
activity data, and there are no human toxicity data on individual PAHs.

Dr. Albert also noted there was no EPA consensus on the inhalation unit risk estimate for BaP
for evaluation of the risks associated with inhalation exposure. The inhalation unit risk value
used by Cal EPA and some EPA regions and program offices is based on a Syrian golden
hamster study by Thyssen and colleagues; however, this value has not been verified by IRIS.
Further, only seven carcinogenic PAHs are sampled, and the source of the environmental
mixture is generally unknown.

Comparison with Other Approaches

Drs. Baird and Nesnow noted that, in their judgment, the surrogate approach method was
preferable to the relative potency factor approach. Several other participants agreed that the
relative potency approach would always underestimate potency and human risk, because it
measured only a few compounds in the mixture. Dr. Nesnow stated that he could not think of a
single reason why one would prefer to use the relative potency approach for the risk assessment
of a complex mixture. The surrogate approach would be more useful if the mixture of interest
had been analytically measured for constituent compounds. Even if the mixture of interest was a
mixture of mixtures, the surrogate approach might still be used with a core group of 4- to -7 ring
PAHs. Dr. Muller added that because the relative potency factor method consistently
underestimated public health risk, its use was not consistent with regulatory mandates to protect
public health. The surrogate approach was preferred if the mixture of interest could be judged to
be sufficiently similar to the surrogate mixture. If this could not be ascertained, then the use of
the relative potency factor approach was the only realistic alternative.

Drs. Nesnow and DiGiovanni agreed that any approach that at some level relates back to a whole
mixture was preferable to the relative potency factor approach. The strength of the surrogate
approach is that it related the toxicity of a mixture of interest to a reference mixture whose
toxicity as a mixture has been characterized. The strength of the comparative potency approach
was that the toxicity of whole mixtures could be characterized without specifically identifying
and quantifying the individual components. Both these approaches accounted for interactions.
Dr. Nesnow stated that the relative potency factor approach should only be used as a last resort.
Dr. Muller further noted that the WHO has concluded that there is no scientific basis for the

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relative potency factor approach; WHO recommends the surrogate approach, with BaP as the
surrogate indicator compound.

Dr. Muller again emphasized that the basis for regulation was protection of public health. An
assessment based on a method known to under estimate risk did not protect public health, nor did
it err on the side of caution. When approaches were compared with regard to associated
uncertainties, the conclusion was that the surrogate approach exhibited considerably less
uncertainty than the other approaches, and was also more conservative. Dr. Mauderly
questioned whether the surrogate approach was appropriate with mixtures which were not judged
to be sufficiently similar to a reference mixture. Dr. Albert noted that there were no good data
available that compared approaches in a systematic manner and recommended that the three
different approaches be compared and evaluated systematically.

Dr. Nesnow suggested that if the mixtures were simple, containing mainly PAHs, then the
relative potency factor approach might be used, although at a minimum, the inclusion of
additional PAH species, with associated exposures and toxicities was necessary. However, Dr.
DiGiovanni commented that in his judgment, the use of the relative potency factor approach was
inappropriate as compared with the use of a mixtures approach for which biological activity data
on the whole mixture were available. Although the use of the relative potency factor approach
might be considered for very simple PAH mixtures, simple PAH mixtures are unlikely to occur
frequently in the environment. Intuitively, he would rather base risk factor analysis on some
data available for a composite mixture and some biological data for that mixture. This approach
would be more accurate and make more sense.

Sufficient similarity is based on strength of evidence. If the confidence is low regarding
similarity of mixtures, Dr. Nesnow suggested that one might want to use the relative potency
factor approach and assume additivity. If there is greater confidence regarding similarity of
mixtures, the surrogate approach is preferred. Dr. Nesnow noted that the use of either approach
involved trading one set of uncertainties for another. For example, the relative potency factor
approach would not be appropriate for cigarette smoke. Dr. Nesnow also expressed
dissatisfaction with the use of coke oven emissions as a surrogate, stating that these emissions
were not similar to combustion mixtures. Dr. Muller noted, however, that when one looked at
different mixtures in terms of composition and potency, the differences were not as large as
might be assumed.

Dr. DiGiovanni emphasized that he is not a proponent of the relative potency factor method for
the following reasons: (1) the basic assumption of the approach is additivity, which is unlikely to
occur; and (3) a common mode of action among all PAHs is inferred by the use of this method,
which is debatable. Thus, the assumptions underlying the relative potency factor approach may
not be valid, and therefore, the method itself may not be valid. Dr. Mauderly questioned what
the experts would do if the choice were to estimate toxic potency of a complex mixture by using
the relative potency factor approach or not to estimate toxic potency at all. Dr. DiGiovanni
replied that he would rather have a toxic potency/risk estimate based on some biological data for
a mixture even if the mixture of interest were not very similar to the standard/reference mixture.
Biological data for a whole mixture included data on interactions, and thus were more relevant
and reliable. If the toxic potency/risk estimate were to be based on a reference mixture, there
would then be some degree of confidence that the biological activity represented the sum of the

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interactions. Dr. DiGiovanni further added that even if all available data were used, this
approach would still be limited because interactions among PAHs and other compounds in the
mixture are not considered. There may be other mixture constituents with different modes of
action which may affect the carcinogenic potency of the whole mixture.

Dr. Thorslund observed that even if additional PAHs or other constituents of a mixture were
monitored, a components approach still does not provide information on the toxicity
characteristics of the whole mixture. If exposure is low, the probability is low that significant
component interaction occurs. However, the potential for interactions increases if exposure is
large; for example, with simultaneous exposure to cigarette smoke and a complex PAH mixture.

Dr. Nesnow stated that perhaps this approach should be used only when the mixture of interest
comes from many sources and there is no reference mixture to enable another approach to be
used (i.e., comparative potency or surrogate approach).

Adequacy of Animal Data Sets

The adequacy of the PAH animal data sets was discussed. Dr. Goldstein suggested that the
toxicity data sets used should be based on chronic exposure. Dr. Nesnow noted that in the case
of dioxin, toxicity equivalent factors were derived from short-term studies, and in his judgment,
chronic exposure studies were not necessary for relative potency estimation. Dr. DiGiovanni
stated that his major concern with the use of chronic studies is that they are conducted with very
high doses whereas tumor initiation/promotion studies are conducted at much lower doses and
thus are more relevant to environmental exposures. He agreed with Dr. Nesnow that mouse skin
painting studies were adequate for the development of relative potency or toxicity equivalent
factors.

Human Relevance of Animal Data

Dr. Goldstein added that the Electric Power Research Institute (EPRI) has estimated toxicity
equivalents for a number of environmental coal tar containing PAHs. BaP, with the highest IRIS
cancer slope factor, dominated the calculations, and accounted for approximately 70% of the
biologic activity in the mixtures. The difficulty was extrapolating from animals to humans; the
toxic potency for BaP was estimated from an oral cancer slope factor derived from a composite
of two oral animal studies. There are no data relating the animal response to responses in
humans; thus, the use of these animal data does not have scientific relevance for human exposure
situations. Dr. Muller suggested that by looking at the effects of coke oven emissions in animals
and humans, the human potency of BaP might be estimated, using back calculations. WHO also
compared the ratios of the toxicity of BaP and the toxicity of a range of whole mixtures, and
showed that these ratios ranged from 1.8 to 8.5. The largest ratio was for cigarette smoke in
which the influence of BaP was relatively small. The range reflected the different contributions
of PAH exposure/toxicity to the exposure/toxicity of mixtures. When WHO used coke oven
emissions as the basis of the comparative analysis, the risk associated with the 4- to 7-ring PAH
fraction overestimated the risk associated with the whole mixture. However, this overestimation
might not have been toxicologically significant because of the modulating presence of other
substances in the mixture. Dr. Muller again noted that this method only predicted the
potency/risk of the PAH fraction of the mixture (i.e., 4- to 7-ring PAH fraction). Additional

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analyses are generally conducted separately on other compounds in the mixture such as nickel,
1,3-butadiene, benzene and others, and all the risks are summed. Thus, interactions are not
assessed by this method.

Assumption of Additivity

It is not clear at this time whether all PAHs act via a single mode of action. Different modes of
action for different PAHs would limit the suitability of the relative potency factor approach for
PAH-containing mixtures. Dr. Nesnow noted that the basic theoretical assumption underlying
the relative potency factor approach is additivity, which can only occur if the mechanism(s) of
action is (are) similar. Most participants agreed that the relative potency factor approach would
only be appropriate if there was a single mode of action for all PAHs of interest. If they are
different, then the potential for synergism exists. It was noted that after 100 years of research,
scientists still do not understand how PAHs induce cancer. All PAHs appear to form DNA
adducts; however, the type of adduct produced may differ among PAHs. At this time, there is
controversy among PAH researchers over the significance of the formation of stable versus
unstable DNA adducts. Also, the role of quinone and other reactive oxygen species in PAH
carcinogenicity is not clear, and there is no current consensus.

The current scientific data are mixed regarding the default assumption of dose additivity. In
studies by Dr. Nesnow which compared the effects of individual mixture constituents with those
of the mixture as a whole, additivity was somewhat dose-dependent; depending on the
concentrations, effects were either additive, greater than additive, or less than additive.

However, the extent of the departure from additivity (greater or less than) was only about 2-fold,
which fell within background noise. Nonetheless, several participants noted that the current
science did not support the assumption of additivity; further, there was concern that other
components of complex mixtures, such as metals, might have antagonistic effects on PAH
toxicity.

Use of Additional/Other Reference Compounds

The use of additional PAHs as reference compounds for the relative potency factor approach was
discussed. Dr. Nesnow noted that, by default, BaP was the only reasonable index compound for
use in this approach because it was the only PAH tested in chronic animal bioassays. It was
recommended that the oral cancer slope factor for BaP be derived de novo from the recent
chronic feeding study in the mouse and that a second chronic feeding study with rats be
conducted. For the inhalation route of exposure, it was recommended that a new chronic
inhalation study be performed according to GLP procedures, and preferably with two species and
two sexes per species. It was suggested that NTP be asked to conduct this study.

Discussion followed about which additional PAH compounds should be measured in a complex
mixture. When toxicity equivalents are calculated, BaP accounts for approximately 70% of the
total cancer risk among the currently-measured PAHs. Other BaP compounds (e.g., thiol BaP)
are very potent but not very prevalent, whereas other compounds are prevalent but not potent.
For example, cyclopenta(c,J)pyrene is present at about ten times the mass of BaP but has only
1/10th the biologic activity. Some compounds are present as artefacts in laboratory samples but
are not observed in environmental mixtures. There are numerous uncertainties with regard to

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PAH speciation and the biological importance of speciated compounds. Dr. Goldstein suggested
that from a public health perspective, all putative PAHs should be included. Dr. DiGiovanni
suggested that the list be re-evaluated and that compounds known to be potent be added. Other
compounds known to be of low potency should be removed; the list should not be open-ended.

It was agreed that better toxicity data on more PAHs were needed, and a greater number of PAH
compounds should be included in the toxicity analysis of whole mixtures. Several participants
noted that, at the very least, the approximately 13 PAH compounds with environmental
monitoring data and estimates of carcinogenic potency should be considered. Dr. Albert noted
that the data used to develop the relative potency factors were almost two decades old. It was
recommended that the current literature should be reviewed; the relative activity of each PAH in
various model systems should be re-evaluated, and the relative potency factor approach
expanded to include more PAHs.

Dr. Muller suggested that for a new mixture, one could assess the 4- to 7-ring PAH fraction;
diverse mixtures have been shown to be very similar with regard to this PAH fraction.

Route-to-Route Extrapolation

Dr. Muller noted that both dermal and oral exposure routes should be considered when exposure
was from soil; however, one could not extrapolate dermal potency from oral potency data, as per
EPA's current guidelines. The current relative potency factors are based only on oral data;
inhalation data are needed to derive an inhalation cancer slope factor and to extend the exposure
characterization to the inhalation route. A multi-route analysis of exposure should also be
conducted - one which includes inhalation and dermal routes of exposure.

With regard to dermal exposure, there are no toxicity values for dermal exposures, and this
constitutes a significant data gap. It was noted that there were very few long-term dermal
exposure studies addressing systemic carcinogenicity, and that these are very old (many
conducted in the 1920's). The mouse-skin tumor initiation studies examine initiation/promotion
in the skin but do not consider systemic toxicity/carcinogenicity. There is a need for animal data
on systemic dermal carcinogenicity; there may be useful data in the current literature, such as
skin penetration studies which describe dermally absorbed doses and rate constants for skin
permeability. Exxon has a data set for which tumors in target organs other than the skin have
been examined in a number of mouse skin-painting studies, and lung tumors have been observed;
these data are either in the open literature or in trade association publications. It was
recommended that all existing data sets relevant to the potential for dermal carcinogenicity in
systemic organs be located and evaluated.

It is not known whether the relative oral potency rankings of the 7 PAHs used in the relative
potency approach would be the same if exposure were via the inhalation route. Dr. Nesnow
noted that there were multiple data sets that might be re-evaluated, including studies which use a
route of administration other than mouse skin. It might be possible to examine all the data and
develop a "joint" toxicity equivalence factor which is more representative of the larger data set.
Relative potency might be estimated from merging of the results from different kinds of studies;
further, the set of PAHs under consideration might be expanded. Some participants felt,
however, that the development of one set of relative potency factors for all 3 routes of exposure

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is complicated and has serious limitations; for example, both local and systemic effects would be
merged. It is also questionable whether different animal models can be justifiably considered to
be comparable and whether all animal models are similarly relevant to humans.

Information Needs

It was suggested that testing needs be prioritized. Issues to address included (1) whether BaP is
still the most suitable compound to test and to use as a reference standard or whether there were
other PAHs that might be more toxic/more prevalent in PAH mixtures, and thus more
appropriate for testing and use as a reference; (2) what chemicals should be presented to NTP for
testing; (3) whether recommendations for testing should be for individual PAHs or for complex
mixtures (e.g., diesel fuel, coke oven emissions, and others) be prioritizied. Dr. Mauderly noted
that the list of relevant PAHs should be revisited — better data and a longer list of compounds
are needed. It was recommended that a group of scientists/regulators review the literature and
develop a priority list of compounds to be tested at a later date, including recommendations of
route of exposure. Dr. Muller suggested that epidemiology data are also needed. Dr. Muller also
recommended additional information needs, specifically the development of transformation
markers - indicative of how much transformation of the mixture occurs between stack emission
and human exposure, and the development of source markers or fingerprints to identify the
mixture sources. It was also suggested that the use of urinary metabolic markers to indicate
exposure to PAHs should be explored.

It was generally agreed that data on PAHs in different media, from different sources, and from
different exposure routes are all important information needs. Media play a role in terms of PAH
bioavailability. Information on the source of the mixture influences the selection of the approach
used for PAH assessment. Additional data on different exposure routes, particularly dermal and
dermal absorption, are needed. Dr. DiGiovanni noted that National Institute for Environmental
Health Sciences (NIEHS) is examining the bioavailability of a range of compounds via different
routes; for skin, isolated human skin cultures are being used. Dr. DiGiovanni also noted that
with regard to individual PAHs, there are some data showing that BaP and
dibenz(c/,/?)anthracene are absorbed through the skin; the degree of absorption in general
depends on the molecular weight of the compound.

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5.0

SUMMARY OF OBSERVER COMMENTS

Larry Rosengrant, a chemist in OSWER who is involved in the development of analytical test
methods, asked the experts whether any test methods are used that analyze for total PAHs, such
as immunoassay tests. This is an approach that OSWER is considering as a possible screening
tool. Dr. Nesnow replied that he is familiar with an ELISA assay that measures PAH adducts but
that this assay is not commonly used.

David Carlson, FDA, noted that tumor promotion is not usually dealt within standard EPA risk
assessments; complete carcinogenicity studies are typically utilized. He asked whether the use
of tumor promotion in PAH risk assessment was an issue. Dr. DiGiovanni replied that tumor
promotion data might be utilized if there are no other data. The best data would be from a low-
dose chronic exposure bioassay; however, chronic exposure data for PAHs are very limited. Dr.
Thorslund noted that BaP does not seem to show tumor promotion.

Dennis Devlin, Exxon-Mobil, noted that the oil industry has evaluated the systemic
carcinogenicity of a number of compounds tested in the mouse skin-painting assay and that lung
tumors have been observed in some of these studies. These results have been published either in
the open literature or in trade association publications, and might be useful to EPA.

27

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6.0

ACTION ITEMS: FUTURE INFORMATION AND RESEARCH NEEDS

Throughout the discussion many recommendations were provided on information that is needed
to improve the risk assessment approaches for PAHs. Some of these comments addressed
evaluating existing data sets while others called for new research or assessments.

Recommendations for future information and research needs included: (1) EPA should convene
a panel to re-evaluate the validity and usefulness of the relative potency factor approach, using
all available data sets; (2) the oral cancer slope factor of BaP should be updated, using the data
from the recent chronic feeding study (Culp et al., 1998); (3) EPA should develop an inhalation
unit risk estimate for BaP, using available data; (4) EPA should commission a new inhalation
study, preferably with two species and two sexes per species, conducted by NTP; (5) the validity
of using BaP as the indicator compound should be re-evaluated; (6) additional carcinogenic
PAHs should be added to the current set of PAHs for which relative potency factors are derived
(EPA, 1993) (suggestions ranged from including all EPA "target" PAHs to adding only PAHs
known to be potent and removing those known to be of low potency); and (7) existing dermal
carcinogenicity studies should be evaluated to obtain information on the absorption and
distribution of PAHs and PAH-containing mixtures, and data on the systemic tumorigenicity of
exposure via this route.

Information needs are numerous and need to be prioritized. Recommendations for additional
specific testing were considered to be beyond the scope of the charge for this peer consultation.
Participants recommended that EPA convene another peer review to review the literature and to
develop a priority list of PAH compounds and PAH-containing mixtures to be tested, as well as
exposure routes for testing (particularly for oral and inhalation routes). Additional
epidemiologic data are also needed. Existing data sets should be re-evaluated to determine the
degree of similarity/difference among complex mixtures. Other suggestions included research
on: (1) the development of markers for characterizing the degree of transformation that occurs
between source emissions and the point of exposure; (2) the development of markers for
identifying sources of mixtures of unknown origins; and (3) the use of urinary metabolites of
PAH compounds, such as 1-hydroxypyrene (a metabolite of pyrene), as biological markers of
exposure.

Particularly for the relative potency factor approach, the following testing should be prioritized:
(1) whether BaP is still the most suitable compound to test and to use as a reference standard or
whether there were other PAHs that might be more toxic/more prevalent in PAH mixtures, and
thus more appropriate for testing and use as a reference; (2) what chemicals should be presented
to NTP for testing; (3) whether recommendations for testing should be for individual PAHs or
for complex mixtures (e.g., diesel fuel, coke oven emissions, and others). In addition, the list of
relevant PAHs should be revisited — better data and a longer list of compounds are needed. It
was recommended that a group of scientists/regulators review the literature and develop a
priority list of compounds to be tested at a later date, including recommendations of route of
exposure.

It was generally agreed that data on PAHs in different media, from different sources, and from
different exposure routes are all important information needs. Media play a role in terms of PAH
bioavailability. Information on the source of the mixture influences the selection of the approach

28

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used for PAH assessment. Additional data on different exposure routes, particularly dermal and
dermal absorption, are needed. The National Institute for Environmental Health Sciences
(NIEHS) is examining the bioavailability of a range of compounds via different routes; for skin,
isolated human skin cultures are being used. With regard to individual PAHs, there are some
data showing that BaP and dibenz(c/,/?)anthracene are absorbed through the skin; the degree of
absorption in general depends on the molecular weight of the compound.

29

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APPENDIX A
List of Participants

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WORKSHOP ON APPROACHES TO Till
HEALTH ASSESSMENT OF PAH MIXTURES
LIST OF EXPERT PARTICIPANTS

Roy Albert, MD

Professor Emeritus

Department of Environmental Health

University of Cincinnati Medical Center

2985 Grandin Rd

Cincinnati, OH 45208

phone: 513-558-0411

fax: 513-558-4397

roy. alb ert@uc. edu

Dr. William M. Baird

Professor, Department of Environmental and Molecular Toxicology

Department of Statistics and College of Veterinary Medicine

1158 Ag Life Sciences Bldg.

Oregon State University

Corvallis, OR 97331

phone: 541-737-1886

fax: 541-737-0497

william.baird@orst.edu

John DiGiovanni, Ph.D.

University of Texas MD Anderson Cancer Center

Science Park - Research Division

Department of Carcinogenesis, Chairman

P.O. Box 389 - Park Road 1C

Smithville, TX 78957

phone: 512-237-9414

fax: 512-237-2522

j digi ovanni @ sprd 1. mdacc. tmc. edu

A-l

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Dr. Kirby C. Donnelly
Associate Professor

Department of Veterinary Anatomy and Public Health

Texas A&M University

College Station, TX 77843

phone: 979-845-7956

fax: 979-847-8981

kdonnelly@cvm.tamu.edu

Dr. Larry Goldstein

Electric Power Research Institute

3412 Hillview Avenue

P.O. Box 10412

Palo Alto, CA 94303

phone: 650-855-2725

lgoldste@epri.com

Joe L. Mauderly, DVM	[ Workshop Chair]

Vice President, LRRI and

Director, National Environmental Respiratory Center

Lovelace Respiratory Research Institute

2425 Ridgecrest Drive SE

Albuquerque, New Mexico 87108

phone: 505-348-9432

fax: 505-348-4983

j mauderl@lrri. org

Dr. Pavel Muller
President, ToxProbe Inc.
215, Wynford Drive, Suite 1801
Toronto, Ontario M3C 3P5
Canada

phone: 416-467-5106
fax:416-423-8276
mullerpavel@home.com

A-2

-------
Dr. Stephen C. Nesnow

U.S. Environmental Protection Agency

Office of Research and Development

Mail Code MD-68

Research Triangle Park, NC 27711

phone: 919-541-3847

email: nesnow.stephen@epa.gov

Dr. Todd W. Thorslund
6013 Jan Mar Dr.

Falls Church, VA 22041
phone: 703-820-2133
demitrathorslund@msn. com

Dr. Stephen A. Wise

Analytical Chemistry Division (839)

National Institute of Standards and Technology

100 Bureau Drive, Stop 8392

Gaithersburg, MD 20899-8392

phone: (301)975-3112

stephen.wise@nist.gov

A-3

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APPENDIX B
List of Observers

-------
PAH WORKSHOP OBSERVER REGISTRATION LIST

Earl W. Arp

Director Health, Safety and Environment

Asphalt Institute

P. O. Box 14052

Lexington, KY 40512

Telephone: 859-288-4976

Fax: 859-288-4999

E-mail: earp@asphaltinstitute.org

Joe Banzer
NEMA

1300 N. 17th St.

Suite 1847
Rosslyn, VA 22209
Telephone: 703-841-3237

Michael Broder

U.S. EPA, ORD, NCEA (8601 D)

Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460
Telephone: 202-564-3393
E-mail: broder.michael@epa.gov

David Carlson
Toxicologist

FDA, Office of Food Additive Safety
200 "C" Street, SW (HFS-225)

Washington, DC 20204
Telephone: 202-418-3046
Fax: 202-418-3126
Email: DCarlson@cfsan.fda.gov

Barbara Davis

U.S. EPA, OSWER/OERR (MC 5203G)

Oil Program Center

Ariel Rios Building

1200 Pennsylvania Ave., NW

Washington, DC 20460

Telephone: 703-603-8823

E-mail: davis.barbara@epa.gov

B-l

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Dennis J. Devlin

Section Head - Lubes, Fuels, Specialties
ExxonMobil Biomedical Sciences, Inc
1545 Route 22 East
Annandale, NJ 08534
Telephone: 908.730.1041
Fax: 262.313.3147

Email: dennis.j.devlin@exxonmobil.com

Joseph Doninger
NEMA

1300 N. 17th St.

Suite 1847
Rosslyn, VA 22209
Telephone: 703-841-3237

Lynn Flowers

U.S. EPA, ORD/NCEA (MS 860ID)

Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460
Telephone: 202-564-1537
E-mail: flowers.lynn@epa.gov

Gary Foureman

U.S. EPA, ORD (MD-52)

National Center for Environmental Assessment

Research Triangle Park, NC 27711

Telephone: 919-541-1183

E-mail: foureman.gary@epa.gov

Lee Hofmann

U.S. EPA, OSWER (MC 5101)

Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460
Telephone: 202-260-2230
E-mail: hofmann.lee@epa.gov

Karen Hogan

U.S. EPA, ORD, NCEA (860ID)

Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460
Telephone: 202-564-3404

B-2

-------
E-mail: hogan.karen@epa.gov

Carl B. Johnson

Toxicologist

FDA/CF SAN/OF AS

200 C St. SW

Washington, DC 20204

Telephone: 202-418-3037

Fax: 202-418-3126

E-mail: cjohnso3@cfsan.fda.gov

Tammy Klein
Hart/IRI

Telephone: 301-354-2023

Arnold Kuzmack

U.S. EPA, OW, OST (4301)

Ariel Rios Building

1200 Pennsylvania Ave., NW

Washington, DC 20460

Telephone: 202-260-5821

Richard Lalumondier
NEMA

1300 N. 17th St.

Suite 1847

Rosslyn, VA 22209

Telephone: 703-841-3237

E-mail: ric_lalumondier@nema.org

Elizabeth Margosches

U.S. EPA, OPPT (7403 M)

Ariel Rios Building

1200 Pennsylvania Ave., NW

Washington, DC 20460

Telephone: 202-564-7636

E-mail: margosches.elizabeth@epa.gov

Paul Matthai

Environmental Protection Specialist

US EPA, OPPT

Washington, DC 20460

Telephone: 202 564-8839

Fax: 202 564-8901

Email: matthai.paul@epa.gov

B-3

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Amy Mills

U.S. EPA, ORD/NCEA (MC 860ID)

Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460
Telephone: 202-564-3204
E-mail: mills.amy@epa.gov

Deirdre Murphy
U.S. EPA, OAQPS (MD-13)

Research Triangle Park, NC 27711
Telephone: 919-541-0729
E-mail: murphy.deidre@epa.gov

Chuck Nace
U.S. EPA, Region 2
290 Broadway

New York, New York 10007-1866

Kathleen W. Nolan
Risk Assessor
ENSR

2 Technology Park Drive
Westford, MA 01886
Telephone: 978-589-3000
Fax: 978-589-3100
Email: knolan@ensr.com

Karen Pollard

EPA/O SW

Ariel Rios Building

1200 Pennsylvania Ave., NW

Washington, DC 20460

Telephone: 703-308-3948

E-mail: pollard.karen@epa.gov

Fred Potter

Hart/IRI

301-354-2019

Sue Rieth

U.S. EPA, ORD (MS 860ID)

Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460

B-4

-------
Telephone: 202-564-1532
E-mail: rieth.susan@epa.gov

Larry Rosengrant

U.S. EPA, OSWER, OSW (5307W)

Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460
Telephone: 703-308-0462
E-mail: rosengraut.larry@epa.gov

Daljit S. Sawhney
U.S. EPA, OPPT (7403)

Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460
Telephone: 202-564-7602
E-mail: sawhney.daljit@epa.gov

Scott Schwenk

U.S. EPA, ORD, NCEA (860ID)

Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460
Telephone: 202-564-6667
E-mail: schwenk.scott@epa.gov

Chingju Sheu, Ph.D.

Toxicology Reviewer
FDA

200 C St, SW
Washington, DC 20204
Telephone: 202-418-3060
Fax: 202-418-3126
Email: cshew@cfsan.fda.gov

Michael Sivak
U.S. EPA Region 2
290 Broadway

New York, New York 10007-1866
Telephone: 212-637-4310
E-mail: sivak.michael@epa.gov

Roy Smith

U.S. EPA, OAQPS (MD-13)

B-5

-------
Research Triangle Park, NC 27711
Telephone: 919-541-5362
E-mail: smith.roy@epa.gov

Michael Vanderveer
FDA, CFSAN, OF AS (HFS-246)
1110 Vermont Ave., NW
Washington, DC 20201
Telephone: 202-418-3004
E-mail: mvanderv@cfsan.fda.gov

Diane D. Wisbeck

Risk Assessor

ARCADIS G&M

1131 Benfield Blvd. Suite A

Millersville, MD 21108

Telephone: 410 987 0032

Fax: 410 987 4392

E-mail: dwisbeck@arcadis-us.com

George M. Woodall, Ph.D.

Senior Toxicologist
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005
Telephone: (202)682-8067
Fax:(202)682-8031
E-mail: woodallg@api.org

B-6

-------
APPENDIX C
Agenda

-------
j V United States

s	I1 Environmental Protection Agency

V***,/ National Center for Environmental Assessment

Peer Consultation Workshop on Approaches to Polycyclic
Aromatic Hydrocarbon (PAH) Health Assessment

Key Bridge Marriott
Arlington, VA
October 24-25, 2001

Agenda

Wednesday, October 24, 2001

8:30 am	Registration

9:00 am	Chair's Opening Remarks, Introductions & Charge to Panel

Joe Mauderly, Chair, Lovelace Respiratory Research Institute

9:25 am	Introduction and Background

Background- Susan Rieth, USEPA, ORD, NationalCenterforEnvironmental Assessment
PAH Assessment in OAQPS - Roy Smith, USEPA, OAR, Office of Air Quality Planning &

Standards

PAH Assessment in OSWER - Lee Hofmann, USEPA, Office of Solid Waste &

Emergency Response

10:00 am BREAK

10:15 am Surrogate Approach - Discussion

Overview- Gary Foureman, USEPA, ORD, National Center for Environmental Assessment

12:00 pm LUNCH

1:00 pm	Comparative Potency Approach - Discussion

Overview - Stephen Nesnow, USEPA, ORD, National Health & Environmental Effects
Research Laboratory

2:15 pm	BREAK

2:30 pm	Relative Potency Factor Approach - Discussion

Overview - Lynn Flowers, USEPA, ORD, National Centerfor Environmental Assessment

4:00 pm	Observer comments

4:30 pm	Discussion Session I - General Discussion

4:50 pm	Closing Comments

Joe Mauderly, Chair

5:00 pm	ADJOURN FOR THE DAY

C-l

-------
Thursday, October 25, 2001

8:30 am	Opening Remarks

Joe Mauderly, Chair

8:35 am	Discussion Session II - General Discussion and Recommendations

10:30 am	BREAK

10:45 am	Discussion Session II (continued)

11:30 pm	Observer comments

12:00 pm	LUNCH

1:00 pm	Discussion Session III - Recommendations

2:45 pm	BREAK

3:00 pm	Wrap-up - Summary of Individual Expert Comments and Recommendations

3:30 pm	ADJOURN

C-2

-------
APPENDIX D
Presenter Overheads

-------
Susan Rieth

D-l

-------
Peer Consultation Workshop
on Approaches to Polycyclic
Aromatic Hydrocarbon (PAH)
Health Assessment

Susan H. Rieth
Integrated Risk Information System

NCEA, ORD

9

JS EPS Office of ResEirCf) and Deve opment

-------
PAH Workshop Steering

Committee

Susan Rieth, Chair, ORD
Vincent J. Cogliano, ORD
Lynn Flowers, ORD
Gary Foureman, ORD
Richard Hertzberg, ORD
Elizabeth L. Hofmann, OSWER
Deirdre Murphy, OAQPS
Stephen Nesnow, ORD
Rita Schoeny, Office of Water
Daniel Stralka, EPA Region 9

v>EPA

p> o	United States

us epa offiRE of Resell aim Development	U"u	Environmental Protection

Agency

-------
Integrated Risk Information

System (IRIS)

•	The IRIS Program develops EPA consensus
scientific positions on potential human health
effects that may result from chronic exposure to
chemical substances found in the environment.

•	Assessments for ~540 chemicals.

•	IRIS assessment of PAHs initiated at the request
of several EPA Program Offices.

OT9

*>EPA

Da	United States

~T"	Environmental Protection

Agency

-------
IRIS Assessments for PAHs

What's Currently on IRIS

•	Entries developed in the early 1990's for 15 non-
methylated PAHs with 3 or more rings ("Priority
Pollutant" list PAHs)

•	Acenaphthene, acenaphthylene, anthracene,
benz[a]anthracene, benzo[a]pyrene, benzo[ib]fluoranthene,
benzo[/c]fluoranthene, benzo[g/7/]perylene, chrysene,
dibenz[aft]anthracene, fluoranthene, fluorene,
indeno[1,2,3-cc/]pyrene, phenanthrene & pyrene

•	Entries for 3 PAH-containing mixtures

•	Coke oven emissions, diesel engine emissions & creosote

Of,1)	v>EPA

p> r	United States

us epa offiRE of Resell aim Development	U" J	Environmental Protection

Agency

-------
IRIS Assessments for PAHs

(con't)

Not Addressed

•	Assessments for other PAHs with carcinogenic
potential (e.g., "supercarcinogens," methylated PAHs
with 3+ rings)

•	Procedure for addressing the environmental
occurrence of PAHs as complex mixtures

•	Consideration of the literature published in the past
decade



*>EPA

DC	United States

"O	Environmental Protection

Agency

-------
History of PAH Assessment

Surrogate Approach

•	Early 1970s - B[a]P proposed as an indicator
(surrogate) of all urban air pollution

•	Subsequent years, B[a]P was used as an indicator of
PAH contamination only

Comparative Potency Approach

•	Early 1980s - proposed as part of an approach for
assessing the carcinogenic risk of PAHs in diesel
emissions

OT9

SEPA

D-t	United States

~ /	Environmental Protection

Agency

-------
History of PAH Assessment

(con't)

Relative Potency Factor Approach

•	1983 — EPA's Ambient Water Quality Criteria Document
presented relative cancer potencies for 5 PAHs; B[a]P
as reference compound

•	Late 1980's and early 1990's - a number of
applications of the methodology

•	1993 — EPA's	Provisional

Risk Assessment	of Polycyclic

OT9

*>EPA

Dp	United States

~ O	Environmental Protection

Agency

-------
2000 Mixtures Guidance

•	EPA Risk Assessment Forum's Supplementary

Guidance	far Canduating

of Chemiaal	Mixtures

•	EPA's risk assessment paradigm for mixtures

OT9

*>EPA

Dq	United States

~	Environmental Protection

Agency

-------
Workshop Objectives

•	EPA is seeking individual scientific opinions on:

•	The extent to which alternative approaches are
supported by the current scientific literature.

•	The applicability of the various approaches for different
exposure situations of interest to EPA.

•	Recommendations for revising existing approaches
consistent with the available toxicological literature.

•	Suggestions for further analyses that might be
undertaken.

OT9

*>EPA

Da pi	United States

~ I U	Environmental Protection

Agency

-------
Roy Smith

D-l 1

-------
PAH Risk

Characterization m the

EPA Office of Air and
Radiation

Roy L. Smith
OAQPS
RTP, NC

D-12

-------
Introduction

Description of OAR's current handling of
PAHs in risk assessments

~	National-scale

~	Urban- or local-scale (e.g., residual risk)
Emphasis

~	Process summaries

~	Our problems

~	Our Q&D solutions

~	Our hopes for better solutions

D-13

RLSmith (10/24/2001)

-------
PAHs Under the Clean
Air Act

Act defines 188 hazardous air

pollutants (HAPs)

~	19 of the 188 are categories, e.g.,
"glycol ethers"

~	One such category is polycyclic
organic matter (POM)

~ "Two or more benzene rings,
boiling point > 100C

~	All PAH compounds are POM, and
therefore HAPs

D-14

RLSmith (10/24/2001)

-------
Risk Assessment
Activities Under the
Clean Air Act

National-scale assessment

~	Guides the air toxics program in prioritizing
HAPs and sources

~	Provides baseline for assessing progress

~	Assists in scoping more refined assessments

~	Inhalation only

Residual risk assessments (local scale)

~	Risk remaining after control technologies are
implemented

~	CAA provides for additional controls if cancer
risk > 1 e-6

~	Oral & inhalation

n_-i c	RLSmith (10/24/2001)

-------
Residual Risk
Assessments: Process

Exposure

~	Begin with best available (e.g.,
state/industry) PAH emissions data for
sources of interest

* Speciated, wherever possible

~	Model dispersion, ambient air &
multimedia concentrations

~	Model inhalation and ingestion exposure
Dose-response

~	Utilize available UREs (inhalation and
oral) for 7 carcinogenic PAHs and RfCs
for miscellaneous PAHs

~	Aggregate cancer risk and noncancer
hazard index for PAHs

n_1fi	RLSmith (10/24/2001)

-------
National-Scale
Assessment: Process

Exposure

~	Begin with national emissions
inventory for POM

~	Model dispersion, ambient air
concentrations

~	Model exposure
Dose-response...

D-17

RLSmith (10/24/2001)

-------
National-Scale
Assessment: Problems

POM Emissions data largely unspeciated

~	Speciation applied ex post facto

Lack of EPA consensus inhalation
inhalation dose-response assessment

~	CalEPA UREs used

Lack of convincing inter-media transport
models for use on national scale, so only
inhalation considered

D-18

RLSmith (10/24/2001)

-------
National-Scale Assessment:
Approach to Dose-Response

Table 2. Residential wood combustion (EPA, 1997, Table 4.1-1, pg. 4-11). Emission factors are
expressed as lb of pollutant emitted per ton of wood combusted.

CHEMICAL NAME

CAS NO

BaP TEF

Emission
Factor
(Ib/t)

Adjusted
EF (Ib/t BaP
eq.)

Percentage
of Total

Acenaphthene

83329

0.00%

0.01

0

0.00%

Anthracene

120127

0.00%

0.014

0

0.00%

Benzo(a)anthracene

56553

10.00%

0.02

0.002

40.65%

Benzo(b)fluoranthene

205992

10.00%

0.006

0.0006

12.20%

Benzo(k)fluoranthene

207089

10.00%

0.002

0.0002

4.07%

Benzo(g,h,i)perylene

191242

0.00%

0.004

0

0.00%

Benzo(a)pyrene

50328

100.00%

0.002

0.002

40.65%

Carbazole

86748

0.52%



0

0.00%

beta-Chloronaphthalene	91587 0.00%	0	0.00%

Chrysene	218019 1.00%	0.012	0.00012	2.44%

D_19	RLSmith (10/24/2001)

-------
Figure 1. D istribution of B aP equivalence am ong 7 carcinogenic PAHs
em itted from 4 large POM sources

-------
Figure 2. Benzo[a]pyrene equivalence
for four large POM sources

D-21

RLSmith (10/24/2001)

-------
Air Toxics Assessments:
Hopes

(1)	OAR is working with states and
others to get speciated POM data into
1999 National Toxics Inventory

~ Expectation that POM will be significant
part of total emissions (and risk),
therefore...

(2)	...An EPA-consensus approach to
PAH dose-response will be crucial

(3)	We also hope that approach can be
extended to non-PAH POM compounds

D-22

RLSmith (10/24/2001)

-------
Lee Hofmann

D-23

-------
PAH Assessment in OSWER

PAH Peer Consultation Workshop

October 24, 2001

Lee Hofmann, Ph.D.

D-24

-------
Provisional Guidance for Quantitative

Risk Assessment of Poly cyclic Aromatic

Hydrocarbons

•	Developed by ORD for Superfund - 1993
- EPA/600/R-93/089

•	7 PAHs: benz[a]anthracene, benzo[b]-
fluoranthene, benzo [k] fluoranthene,
chyrsene, dibenz[a,h]anthracene,
indeno [1,2,3 -cd]pyrene

•	Relative potency approach

D-25

-------
Chemicals Contributing to
Carcinogenic Risk at SF Sites

•	#7 - Benzo[a]pyrene

•	#10 - Benzo[b]fluoranthene

•	#11 - Benz [a] anthracene

•	#14 - Chrysene

•	# 17 - B enzo [k] fluoranthene

•	#22 - Ideno[l,2,3-cd]pyrene

•	#39 - Dibenz[a,h]anthracene

D-26

-------
Gary Foureman

D-27

-------
Overview & Example of "Surrogate Approach"
in Evaluating Exposures to PAH Mixtures

Gary L. Fo
US EPA

Hazardous Pollutant Assessment Group

RTP, NC

AEPA

-------
IDEAL ASSESSMENT OF A MIXTURE

Human Exposure Information

to

the "Mixture of Interest"

with

D-R of Effects in Humans

AEPA

-------
REALISTIC ASSESSMENT OF A MIXTURE

Human/Animal/no Exposure Information

to

Substitut	d" Sufficiently

Surrogate Mixture

with

Little/Incomplete D-R of Effects in
Humans or Animals

AEPA

-------
Sufficiently
Similar
Mixture

Assess Data Quality
adequate

Mixture
of Concern

V

Sufficiently
Similar
Mixture

Group of
Similar
^ Mixtures y

^ >/

Mixture
RfD/C;
Slope
Factor

Only Qualitative Assessment

Components

T . \ /I

Toxicologically
Similar

Toxicologically
imilar

/ \

\/
Toxicologically

Independent

Comparative

Environmental

Potency

Transformation

Hazard
Index

Relative
Potency
Factors

Response
Addition

Interactions
Hazard
Index

Compare and Identify Preferred Risk Assessment,
Integrate Summary with Uncertainty Discussion

AEPA

2001 Guidance

The different types of mixtures assessments based on the availability and quality of the data.
All possible assessment paths should be performed.

D-31

-------
Key Concepts: Assumption of Similarity

•	Sufficiently Similar Mixture (e.g., diesel emissions)

-	A mixture close in composition to the "mixture of concern"

-	Small differences in their components and their proportions

•	Similar Components (e.g., liver toxicants at a Superfund site)

-	Individual chemicals within a mixture

-	Act by same mode-of-action; similarly shaped dose-response curves

•	Group of Similar Mixtures (e.g., dioxins, PCBs)

-	Chemically related classes of mixtures, closely related chemical
structures

-	Act by similar mode-of-action

-	Occur together routinely in environmental samples

&EPA	D 32

-------
"Surrogate" Approach for PAH Mixture

Assessment

Use of Surrogate or

Sufficiently Similar Mixture of PAH

AEPA

-------
Relevancy of PAH Surrogate

•	Individual PAH

•	Potent Component (BaP)

•	Several Selected PAHs

•	Mixture 1 of PAHs

•	Mixture 2 of PAHs

•	nth Mixture of PAHs

1 I

•	"Mixture of Interest"

j*EPA	D-34

-------
Relevancy of PAH Surrogate

• Some Bases for Surrogate Mixture "Similarity"

-	similar by Mode-of-action

-	similar by source

-	similar by specific potent component (e.g., BaP)

-	similar by presence of certain PAH

-	similar by proportion of certain PAH

-	similar by presence/absence of other contributory
components (nitro- or alky-PAH)

AEPA

-------
Relevancy of PAH Surrogate

• Some considerations for choice of
PAH surrogate mixture?

-	Are components monitored? (few are)

-	Are components found in the
environment

-	Toxicologic vs analytic data base?

-	Components may be super- to
noncarcinogenic

-	Interactions ???

-	Other contributory components

&EPA	D-36

-------
Example and Use
of Surrogate Approach

AEPA

-------
Surrogate Mixture Example

(Foureman & Smith, 1999)

44

Mixture of
Concern'

55

Human Risk from
Mixture of Concern

44

55

AEPA

D-38

-------
Surrogate Mixture Example

(Foureman & Smith, 1999)

where

u

Mixture of
Concern



Surrogate
Mixture

and therefore

u

risk

Mixture of
Concern



risk

Surrogate
Mixture

AEPA

D-39

-------
Surrogate Mixture Example

(Foureman & Smith, 1999)

Surrogate
Mixture

Coal Tar Pitch (CTP)

-	PAH & PAH ratios in SRM 1597

-	air values of PAH given by Heinrich (1994)

AEPA

-------
Surrogate Mixture Example

(Foureman & Smith, 1999)

where

risk

Surrogate
Mixture

Inhalation Unit Risk (IUR)
of CTP (Heinrich, 1994) -

1 x 10"4 / (l//g CTP/m3)

AEPA

D-41

-------
General	CTP

-	Are components
monitored? (few are)

-	Are components
found in the environment

- Toxicologic vs
analytic data base?

-	Components may

be super- to
noncarcinogenic

- Interactions

-	Other components

-	"PAHs of Concern"are

routinely monitored

-	"PAHs of Concern" are

in the environment

-	Some chronic animal

studies with CTP

-	SRM 1597 complete

analysis

-	tested as a the mixture

-	SRM 1597 analysis

AEPA

-------
Surrogate Mixture Example

(Foureman & Smith, 1999)

•	Individual PAH

•	Potent Component (BaP)

•	Several Selected PAHs

•	Mixture 1 of PAHs

•	Mixture 2 of PAHs

•	nth Mixture of PAHs

1 I

^ r •	"Mixture of Interest"= CTP

&EPA	D-43

-------
Surrogate Mixture Example

(Foureman & Smith, 1999)

• Some Bases for Surrogate Mixture being

"Sufficiently Similar"

- similar by etc.

-all PAH mixtures = CTP (or

dilutions thereol)

AEPA

-------
Surrogate Mixture Example

(Foureman & Smith, 1999)

u

Mixture of
Concern



BaP @1.2 ng/m3
CHR @5 ng/m3

Human Risk from
Mixture of Concern

9

AEPA

D-45

-------
Surrogate Mixture Example

(Foureman & Smith, 1999)

where

BaP @1.2 ng/m3
CHR @5 ng/m3

[BaP] & [CHR]
ofCTP

and 17.7 ng BaP/m3 in 1 /^g CTP/m3 (Heinrich, 1994)

BaP @1.2 ng/m3
CHR @5 ng/m3

AEPA

D-46

-------
ArpA Table 6. Information for determining cancer risk estimation*1 of

air values for PAHs of concern. (From Foureman and Smith, 1999).

PAHs of Concern

SRM1597
Ratio

ng PAH/m3 /
1 //g CTP/m3

TEFs

Example 5

benzo(a)pyrene

1

17.7

1

1.2

benz(a)anthracene

1

22.3

0.1



benzD(b)fluoranthene

0.7

8.8

0.1



benzo(k)fluoranthene

0.4

7b

0.1



indeno(l,2,3-c,d)pyrene

0.6

11.2

0.1



chrysene

0.8

22.7

0.01

5.0

dibenz( a,h)anthracene

_

_

5













Total



89.7 ng/m3





a Inhalation Unit Cancer Risk = 1 xlO"4 per (jug CTP/m3). b Estimated from SRM 1597 ratio to BaP.

D-47

-------
Surrogate Mixture Example

(Foureman & Smith, 1999)

therefore

1 x 10'4 per
1 jugCTP/m3

u

Risk

Mixture of
Concern

.9?

7 x 10"6

&EPA

D-48

-------
Surrogate Mixture Example

(Foureman & Smith, 1999)

u

Mixture of
Concern



not similar by presence of certain PAH
not similar by proportion of certain PAH

$

risk

Surrogate
Mixture

AEPA

-------
Surrogate Potent Component Example

(Muller et al., 1997)

u

Mixture of
Concern'





not similar

Surrogate Mixture
with

Potent Component (BaPS)

Individual PAH Model

AEPA

-------
Summary - the Charge Questions

•	What are important considerations in judging
whether a PAH mixture is "sufficiently similar" to a
given surrogate for which D-R data are available?

•	Of the available data sets, which is (are) most
appropriate for estimating the potency of a PAH
mixture? Which would not be appropriate?

AEPA

-------
Summary - the Charge Questions

•	What are some of the limitations?

•	Are there clear examples of when this approach is
or is not applicable?

AEPA

-------
Summary - the Charge Questions (con't)

•	Is there a surrogate (a single PAH, a group of
key PAHs, or a certain mixture) that can be
viewed as appropriate for all carcinogenic
PAHs?

•	For what kinds of exposures/situations is this
approach applicable? Could it be considered
the preferred (or only viable) approach?	

AEPA

-------
Stephen Nesnow

D-54

-------
MOUSE SKIN TUMORS AND HUMAN LUNG CANCER FOR
INDIVIDUAL PAH AND COMPLEX PAH CONTAINING MIXTURES

-------
SKIN CARCINOGENESIS BY ORGANIC
EXTRACTS OF PARTICULATES: Historical Summary

Particulate
Source

Mouse Strain

Tumor Type*

Reference

Ambient

Swiss ICR
C57 Dlack

Car* Pap
Car; Pap

Wynder 6 Hoffmann, 1965
Kotin et ol, 1954

Coal Chimney
Soot

"White"

Car; Pap

Passey, 4922
Campbell, 1939

Diesel Engine

C57 Dlack
A

Car» Pap

Kotin et al, 4955
Kotin et al, 1955

Gasoline Engine

C57 Dlack
Swiss

Car; Pap
Car; Pap

Kotin et al 1954
Wynder Cr Hoffmann, 1962

Industrial
Carbon Dlack

Swiss

Car; Pap

Von Hoam & Mellette,
1952

Oil Shale Soot

"White"

Car; Pap

Vosamae, 1979

Road Dust

—

Car; Pap

Campbell, 1909

*Car = Carcinoma
Pap = Papilloma

-------

-------
THE CONSTANT RELATIVE POTENCY ASSUMPTION

K

—

POTENCY I LUNQ CANCER IN MAN ] OF X
POTENCY [ LUNG CANCER IN MAN ] OF Y

POTENCY I MOUSE SKIN 1 OF X
POTENCY I MOUSE SKIN ] OF Y

-------
HUMAN RESPIRATORY CARCINOGENS

COKE OVEN EMISSIONS

[MAZUMDAR ET AL-, 1975]

ROOFING TAR EMISSIONS

IHAMMOND ET Al_ 1976]

CIGARETTE SMOKE EMISSIONS

[DOLL AND PETO, 1978]

DIESEL ENGINE EMISSIONS

[GARSHICK ET AL, 1967, 1988]

-------
DIESEL AND GASOLINE SAMPLES

Sample

Description

Fuel

Driving Cycle

Diesel







Cot

Caterpillar 0004

Diesel No. 2

Mode II

Nissan

Nissan Datsun 220C

Diesel No. 2

HWFET

Olds

Oldsmobile 050

Diesel No. 2

HWFET

VW Rabbit

VW Rabbit

Diesel No. 2

HWFET

Mercedes

Mercedes 000D

Diesel No. 2

HWFET

Furnace

Residential Furnace

Diesel No. 2

10 mln on/20 min off

Gasoline
Mustang

Ford Van

1978 Mustang, U-002 r
V-8 catalyst and EGR

4970 Ford Van,
6 cylinder

Unleaded gasoline
Leaded gasoline

HWFET
HWFET

-------


COMPARATIVE SOURCES

CIGARETTE:

CIGARETTE SMOKE CONDENSATE



2R1 KENTUCKY REFERENCE CIGARETTE

COKE:

COKE OVEN AMBIENT SAMPLE



REPUBLIC STEEL, GADSDEN



AMBIENT SAMPLING ON TOP THE BATTERY

ROOF TAR:

ROOFING TAR EMISSION SAMPLE



TAR POT PARTICULATE EMISSIONS



PITCH-BASED TAR

-------
MOBILE SOURCE, COKE OVEN & ROOFING TAR EMISSIONS

SOXHLET
EXTRACTION

OICHLOROMETHANE (DCM)

DCM, SOLVENT REMOVAL

| EVAPORATION

BIO ASS AY SOLVENT ADDITION

OTHER BIOASSAYS

ACETONE

SKIN CARCINOGENESIS
SYRIAN HAMSTER EMBRYO ASSAYS

-------
RESPONSE OF CARCINOGENS IN HUMANS, ANIMALS, AND MOUSE SKIN

Arsenic

Asbestos

Beryllium

Carbamates

Chtoromethyfethars

Chromium

Coke oven

fsopropyl oil

MOCA

Mustard gas

Nickel

Nitrosamines
Polycyclic aromatic*
Quinolines
Radiation
Vinyl chloride

Occupational
respiratory carcinogen

-------
COMPARISON OF THE TUMOR INITIATING ACTIVITY
OF BENZO(o)PYRENE IN THREE MOUSE STRAINS

Strain

D(a)P Dose, /j 9 Paplllomas/Mouse0

50 .4
25.2
12.5
2.5

50.4
25.2
12.6
2.5

404

202
101
50.4
25.2
12.6

Fromi DIGiovannl •( ol. 1960» Staga and K#$now. unpublished observations
0 Scored ot 6 months

C57 Block

Mice with Papillomas,
percent0

100
60
60
42

-------
MOUSE SKIN TUMOR (GENESIS BIOASSAYS

PROTOCOLS

TEST
AGENT

TUMOR INITIATION

TUMOR PROMOTION

COCARCINOGENESIS

COMPLETE CARCINOGENESIS

B(a)P

TEST
AGENT
+ B(a)P

TPA, 2* WEEKLY

I TEST AGENT, WEEKLY ,

I TPA, 2k WEEKLY

I TEST AGENT, WEEKLY

WEEK OF EXPERIMENT
I

I
I

SCORE
FOR
PAPILLOMAS

-------

-------
Environmental Sample Description

Type

Tar

Sample

Coke Oven

Roofing Tar

Cigarette Smoke
Diesel

Particulate Emission
Condensate
Particulate Emission

Sampling Apparatus

Separator in Coke
Oven Battery

Baghouse

Acetone—Cold Trap

Pal If lex-Teflon
Coated Fiberglass
Filter

-------
TEST AGENT CODE: 0031 PROTOCOL! TI
TEST AGENT NAMES NISSAN DCM 1979

DOSE

•NICE

JsPAPS

7555"

lis""

"37583

100.000

39

2.564

500.000

39

23.077

1000.000

38

39.474

2000.000

40

57.500

10000.000

30

97.368

NQNUN POISSON MODEL HITN BACKGROUND

ESTIMATES

BETA INITIAL

"o" *0593
-1.7472
2 *3138

FINAL ASYH UAR

•	0479
•7.1132

•	9624

• 0003
.1688
.0022

TEST

POISS
ADQCY
DOSE

CHI-SQ

326.69
9.01
674.83

306 .1990
3 .8291
2 .0000

PAPS/H ff 1 NG

• 676

LONER 93% UPPER

.373	.790

.521	.797

STRAIN; S SEX! F WEEKS 26
START DATES 072079

MEAN

*7059*

.026
.383
. 526
1.600
5.658

3. D.

"7271

.160
.847
.762
1.892
3.656

OBS t EXP US DOSE

5000

MICROGRAMS

-------
Induction of Papillomas In SENCAR Mouse Skin under a Tumor Initiation Protocol



Paplllomas/mouse

Relative

Carcinogen

at 1 mg organic*

Rank

Coke Oven

2,1

1.0

Roofing Tar

0.40

0.20

Diesel

0.31

0.16

Cigarette Smoke

0.0024

0.0011

Albert et a I, 1983

-------
Induction of Papillomas In SENCAR Mouse Skin under a Tumor Initiation Protocol

Carcinogen

TD25, Dose In
mg yielding
25X mice
with papillomas

Relative
Rank

Coke Oven

0.16

1.0

Roofing Tar

0.71

0.22

Diesel

1.0

0.16

Cigarette Smoke

92

0.0017

•t al, 1003

-------
Human Lung Cancer Unit Risks for Three Complex Mixtures

Emission Source

Human Lung Cancer Unit Risk

Relative Rank



-4



Coke Oven

9.3 x 10

1.0



-4



Roofing Ter

3.6 x 10

0.39



-6



Cigarette Smoke

2.2 x 10

0.0024

Albert *1 al, 1983

-------
RELATIONSHIP BETWEEN MOUSE SKIN TUMORS AND HUMAN LUNG CANCER

°o

* 7
<2

DC ?

< §
« s

s 5

< o



2,5

0.6

0 0.9 t 1.5 2 2.5 3 3.5 4

MOUSE SKIN TUMOR INITIATION

LOO [ PAPILLOMAS/MOUSE/MG 0RQANCS.103 )

-------
EXTRAPOLATION OF RAT DIESEL INHALATION STUDY

MAUDERLY RAT DIESEL INHALATION DATA APPLIED TO
THE LINEARIZED MULTISTAGE EXTRAPOLATION MODEL

ALL TUMORS INCLUDED EXCEPT SQUAMOUS CYSTS

POTENCY EXPRESSED AS THE UNIT RISK

[INDIVIDUAL LIFETIME EXCESS LUNG CANCER RISK FROM CONTINUOUS
EXPOSURE TO TO 1 MICROGRAM CARCINOGEN /CUBIC METER OF INHALED AIR]

-5	3

UNIT RISKi 1.2 X 10 LIFETIME RISK /ug PARTICULATES /M

-4	3

UNIT RISKi 0.7 X 10 LIFETIME RISK /ug ORQANICS /M

ALBERT AND CHEN, 1086

-------
Human Lung Cancer Unit Risks for Four Complex Mixtures

Emission Source

Human Lung Cancer Unit Risk Relative Rank

Coke Oven

-4

9.3 x 10 1.0

Roofing Tar

-4

3.6 x 10 0.39

Diesel

-4

0.7 x 10 0.075

Cigarette Smoke

-6

2.2 x 10 0.0024

Albert et al, 1963

-------
RELATIONSHIP BETWEEN MOUSE SKIN TUMORS AND HUMAN LUNG CANCER

®o

-------
K Constants for Pairs of Human Respiratory Carcinogens

Roofing Ter

Diesel

Cigarette Smoke

Coke Oven

2.0

0.51

2.1

Roofing Tar

—

0.25

1.0

Diesel

4.0

Calculated from each unlqua pair of human respiratory carcinogens using the
mouse skin tumor multiplicity and human cancer unit risk data. By convention^
the more active agent was placed In the numerator,

Nesnow, 1989

-------
-------
Lynn Flowers

D-78

-------
RELATIVE POTENCY FACTOR
APPROACH FOR THE
HEALTH ASSESSMENT OF
PAH MIXTURES

Lynn Flowers

National Center for Environmental Assessment
Office of Research and Development
Washington, DC

fiin

Mm _ _ _ United States

D-79 Environmental Protection

¦JS EPA Offine of Reswrth and Devs opment Agency

SEPA

-------
BASICS OF THE RELATIVE
POTENCY FACTOR APPROACH

¦ Based on the toxicity of select individual components
of mixtures

¦ Eliminates the issue of complex differences between
PAH mixtures; presents a compromise in that toxicity
of other key components and interactive effects may
not be considered

¦ Estimate risk by assigning relative values to select
individual PAH which are known to play a role in
toxicity and for which toxicity data are available

*>EPA

Dp r\ United States

~OU Environmental Protection

Agency

-------
Selected Applications

¦ EPA/ORD (1993) Provisional Guidance for

Quantitative Risk Asses

Aromatic Hydrocarbons

¦ Nisbet and LaGoy (1992)

¦ California EPA (1999)

¦ Ontario Ministry of the Environment (1997)

*>EPA

Dp A United States

~ O I Environmental Protection

Agency

-------
EPA 1993 Provisional Guidance

¦ B[a]P used as the standard PAH with the
highest ranking

¦ "Estimated order of potential potency" of 6
PAH determined relative to B[a]P

¦ Order of magnitude rankings (B[a]P = 1.0)

¦ All 7 PAH classified as B2 carcinogens by
IRIS Program

*>EPA

Dp O United States

Environmental Protection
Agency

-------
EPA 1993 Provisional Guidance

¦ Based on data from complete
carcinogenesis assays in mouse skin

¦ Assumption of additivity of PAH
response

¦ Application relegated to cancer risk and
oral exposure only

*>EPA

Dp O United States

"OO Environmental Protection

Agency

-------
Example Application

¦ Cancer risk posed by individual PAH
from a mixture is expressed relative to
B[a]P

¦ Individual PAH cancer risks are summed
to estimate PAH mixture cancer risk

*>EPA

Dp A United States

"04 Environmental Protection

Agency

-------
Example Application:
Adult Recreational Exposure
Soil Ingestion

PAH

RPF

Slope Factor

(mg/kg-day)-1

Soil Cone.

(mg/kg)

Cancer Risk

Benzo[a]pyrene

1.0

7.3

6.4 x 10"5

Dibenz[a,/7]anthracene

1.0

7.3

4.3 x 10"5

Benz[a]anthracene

0.1

0.73

8.6 x 10"7

Benzo[jb]fluoranthene

0.1

0.73

2.1 x 10"6

lndeno[7,2,3-c,c/]pyrene

0.1

0.73

8.6 x 10"7

Benzo[/c]fluoranthene

0.01

0.073

3.4 x 10"7

Chrysene

0.001

0.0073

Total

4.3 x 10"8
1 x 10"4

OTO

JS EPA Offre of ResuarCh and Deve opmunt

D-85

vvERA

United States
Bivlronmental Protection

Agency

-------
Charge Questions

¦ What are the important issues to consider in developing an
application of the RPF approach?

¦ What are important factors to consider in determining which
PAH to include in a RPF scheme? (e.g., weight-of-evidence of
carcinogenicity; chemical structure (QSAR); mode/mechanism
of action; availability of certain types of studies, such as in
vivo cancer bioassays, etc.)

¦ Should a RPF scheme take into account evidence that PAH
appear to induce different types of DNA damage via more
than one mode of action? If so, how can this be
accomplished?

*>EPA

Dots United States

"OO Environmental Protection

Agency

-------
Charge Questions

(con't)

¦ B[a]P has traditionally been used as the standard PAH to which
the tumorigenic potency of other PAH has been related. Does
the current science support the continued use of B[a]P as the
standard for all exposure routes, especially in the context of the
more newly discovered highly potent species of PAH? If so, what
data should be used to establish a cancer slope factor for B[a]P
by the oral route? By the inhalation route? By the dermal route?

¦ Which assay systems (including whole animal, are most
relevant for developing RPFs? Should a "joint analysis," where
data sets are combined, be attempted?

*>EPA

Dp "7 United States

- O / Environmental Protection

Agency

-------
Charge Questions

(con't)

¦ What are the limitations associated with developing one set of
RPFs for all three routes of exposure (i.e., inhalation, oral &
dermal)? What are important considerations in developing RPFs
for each route?

¦ EPA's 1993 Provisional Guidance adopted the assumption that
the carcinogenicity of individual PAH is additive. Is the default
assumption of dose additivity supported by the current science?

¦ For what kinds of exposure situations is this the preferred (or only
viable) approach?

*>EPA

Dp O United States

"OO Environmental Protection

Agency

-------
APPENDIX E

Workshop on Approaches to Polycyclic Aromatic Hydrocarbon (PAH)
Health Assessment - Discussion Document

-------
NCEA-3-1105
September 2001
Discussion Document

Workshop on Approaches to
Polycyclic Aromatic Hydrocarbon (PAH)
Health Assessment

Discussion Document

National Center for Environmental Assessment - Integrated Risk Information System

Office of Research and Development
U.S. Environmental Protection Agency
Washington, DC 20460

-------
DISCLAIMER

This document has been reviewed in accordance with U.S. Environmental Protection
Agency policy and approved for publication. Mention of trade names or commercial products
does not constitute endorsement or recommendation for use.

9/18/01

DISCUSSION DOCUMENT

-------
CONTENTS

AUTHORS, CONTRIBUTORS. AND REVIEWERS v

I. INTRODUCTION 1

A. Background 1

B. Charge to Workshop Participants 1

II. BACKGROUND INFORMATION ON PA I Is 3

A. Overview of PAHs 3

B. Health Effects Data 3

C. Environmental Monitoring 4

III. CURRENT EPA PRACTICES FOR ASSESSING PAH HEALTH RISK 7

A. Guidance Developed by EPA's Office of Research and Development (ORD) 7

1. Toxicity Assessments for Individual PAHs in IRIS 7

2. Assessments for PAH Mixtures 9

B. Current Practices within EPA Program Offices 11

1. Office of Air and Radiation 12

2. Office of Solid Waste and Emergency Response (OSWER) 12

IV. APPROACHES TO HEALTH ASSESSMENT FOR PAH MIXTURES 14

A. Introduction 14

B. Surrogate Approach (Using Data for Sufficiently Similar Mixtures) 16

C. Comparative Potency Approach (Based on Data for a Group of Similar Mixtures)... 17

D. Relative Potency Factor Approach (Component Approach) 18

V. CHARGE QUESTIONS 21

A. Surrogate Approach (Using Data for Sufficiently Similar Mixtures) 21

B. Comparative Potency Approach (Based on Data for a Group of Similar Mixtures) ... 22

C. Relative Potency Factor Approach (Component Approach) 23

D. General Questions 25

REFERENCES 26

APPENDICES

Appendix A. PAHs Included on Selected Monitoring and Assessment Lists
Appendix B. Surrogate Approach Developed by Foureman and Smith (1999)

9/18/01

DISCUSSION DOCUMENT

-------
TABLES

Table 1. Summary of PAH Assessments Currently in IRIS 8

Table 2. Estimated Order of Potential Potencies 10

Table 3. Summary of Major Features of Existing PAH Assessment Approaches 15

9/18/01

DISCUSSION DOCUMENT

-------
AUTHORS, CONTRIBUTORS, AND REVIEWERS

This document was prepared by the PAH Workshop Steering Committee:

Chair and principal author:

Susan Rieth, Office of Research and Development

Workshop Steering Committee and contributing authors:

Vincent J. Cogliano, Office of Research and Development

Lynn Flowers, Office of Research and Development

Gary Foureman, Office of Research and Development

Richard Hertzberg, Office of Research and Development

Elizabeth L. Hofmann, Office of Solid Waste and Emergency Response

Deirdre Murphy, Office of Air Quality Planning and Standards

Stephen Nesnow, Office of Research and Development

Rita Schoeny, Office of Water

Daniel Stralka, EPA Region 9

9/18/01

DISCUSSION DOCUMENT

-------
I. INTRODUCTION

A. Background

At the request of several U.S. Environmental Protection Agency (EPA) program offices, the
EPA Integrated Risk Information System (IRIS) Program is undertaking a health assessment for
polycyclic aromatic hydrocarbons (PAHs). The IRIS Program develops EPA consensus
scientific positions on potential human health effects that may result from chronic exposure to
chemical substances found in the environment; assessments for approximately 540 chemical
substances can be found in the IRIS database.

Currently, the IRIS database contains entries developed in the early 1990s for 15 non-
methylated PAHs with three or more rings. These entries provide assessments of the
carcinogenic and noncarcinogenic effects of individual PAHs; however, the IRIS database does
not provide assessments for other PAHs with carcinogenic potential (e.g., "supercarcinogens,"
methylated PAHs, etc.), and does not consider issues associated with the environmental
occurrence of PAHs as complex mixtures.

The objective of the IRIS Program in conducting a health assessment for PAHs is to provide
assessments of the carcinogenic and noncarcinogenic properties of PAHs occurring as mixtures.

The initiation of the IRIS PAH assessment follows closely on the release of the EPA Risk
Assessment Forum's Supplementary Guidance for Conducting Health Risk Assessment of
Chemical Mixtures (EPA, 2000a), which sets forth EPA's risk assessment paradigm for
mixtures. The framework for chemical mixture assessment provided in the supplemental
guidance will be applied in the current IRIS effort.

B. Charge to Workshop Participants

Because of the complexity of the scientific literature related to PAH mixtures, the IRIS
Program is sponsoring a two-day peer consultation workshop with experts in PAH toxicology
and the assessment of chemical mixtures to examine alternative approaches to the health
assessment of PAH mixtures. Because information needed to support development of a mixtures
approach for assessing the noncancer effects of PAHs is limited or lacking, it is expected that the
workshop will largely focus on the extensive carcinogenicity literature for PAHs.

EPA is asking workshop experts to consider the alternative approaches to PAH health
assessment presented in this document and to offer their scientific opinions on the extent to
which each approach is supported by the current scientific literature. Expert opinion will also be
sought on how well the approaches address the range of exposure situations and monitoring data
encompassed by EPA program offices. The expert opinions and recommendations generated in
this workshop will be taken into consideration by EPA in developing an appropriate and

9/18/01

DISCUSSION DOCUMENT

-------
scientifically defensible health assessment procedure(s) that can be used in combination with
exposure assessment information to evaluate the potential health risk of PAH mixtures.

The remainder of this document presents background information on PAHs and on current
EPA regulatory approaches to PAH health assessment, and provides specific charge questions
that the workshop participants may wish to consider during the two-day workshop.

9/18/01

DISCUSSION DOCUMENT

-------
II. BACKGROUND INFORMATION ON PAHs

A. Overview of PAHs

The term "polycyclic aromatic hydrocarbon" (PAH) refers to a large class of organic
compounds formed during the incomplete combustion of coal, oil, gas, wood, and other organic
substances. PAH has been variously defined to include organic compounds containing either
two or more, or three or more, fused rings made up of carbon and hydrogen atoms (i.e.,
unsubstituted parent PAH and their alkyl-substituted derivatives) (IPCS, 1998; Schoeny et al.,
1998). The more general term "polycyclic aromatic compound" also includes functional
derivatives (e.g., nitro- and hydroxy-PAHs) and the heterocyclic analogs that contain one or
more hetero atoms (i.e., atoms other than carbon and hydrogen) in the aromatic structure (IPCS,
1998). More than 100 different PAHs have been identified in atmospheric particulate matter and
in emissions from coal-fired residential furnaces, and about 200 have been found in tobacco
smoke (IPCS, 1998). Because PAHs generally occur in the environment as complex mixtures
and because many have similar toxicological, structural, and environmental fate properties, they
are often evaluated as a single class. For purposes of the current undertaking, EPA is limiting
the universe of PAHs to include those PAHs consisting of three or more fused rings, methylated
or non-methylated, and to exclude all compounds with anything other than carbon and hydrogen
in their compositions.

B. Health Effects Data

Reliable health effects information exists for relatively few of the individual PAHs, and this
information is limited to data from various experimental models.1 Thus, the potential health
effects of the less-well studied PAHs must be inferred from the group as a whole.

Supplementing these data on individual PAHs is human and animal health effects literature for
various PAH-containing mixtures (e.g., coke oven emissions, emissions from smoky coal
burning, and coal tar residues); however, because chemicals other than PAHs occur in these
complex mixtures, the observed toxicity cannot necessarily be ascribed to PAHs.

C. Environmental Monitoring

Environmental occurrence of PAHs, as a measure of exposure potential and thus one
determinant of potential risk, is relevant to the identification of those PAHs that will be the focus

'The International Programme on Chemical Safety (IPCS, 1998) selected for evaluation
33 individual compounds based on the availability of relevant toxicological and exposure data;
the Agency for Toxic Substances and Disease Registry (ATSDR, 1995) considered data to be
reliable for only 17 PAHs.

9/18/01

DISCUSSION DOCUMENT

-------
of EPA's review. Unfortunately, the large body of environmental monitoring data for PAHs
suffers from some significant limitations. Although PAH-containing mixtures can contain
hundreds of constituents, most monitoring programs routinely report analytical results for only
17 PAHs.2 Historically, 16 of the 17 PAHs were included on the Priority Pollutant List
generated in the 1970s under provisions of the Clean Water Act. These PAHs were subsequently
included on the Contract Laboratory Program (CLP) Target Compound List (TCL), a list of
chemicals for which monitoring is routinely performed at Superfund and other waste sites.
(Organic chemicals on this list are referred to as target compounds.) There are many PAHs,
some now recognized as more toxic than those on the TCL, for which routine analysis is not
performed. The remainder of this section is not intended to provide a complete or necessarily
representative characterization of current PAH monitoring data, but rather to highlight some
issues to be considered when comparing those PAHs for which routine monitoring is performed
and those PAHs with a relatively high carcinogenic potential.

As noted above, PAHs identified in various combustion products include those for which
routine analysis is performed and others for which analysis is not routinely performed. For
example, analysis of indoor air samples (particle-phase organics) from a mobile home with a
kerosene heater identified 10 target compound PAHs, two non-target compound (non-
methylated) PAHs, and four nitro-PAHs (Mumford et al., 1991). Cyclopenta[cd]pyrene, one of
the two non-target compound PAHs and a demonstrated carcinogen in experimental animal
models, comprised approximately 5 percent of the mass of particle-phase PAHs analyzed. PAH
analysis of the organic extract of indoor air particles from smoky coal combustion3 in four homes
in Xuan Wei, China during cooking revealed 10 target compound PAHs, six non-target
compound (non-methylated) PAHs, three methylated PAHs, and two heterocyclic PAHs
(Mumford et al., 1995). Cyclopenta[c6/]pyrene was also present in smoky coal emissions,
comprising approximately 3 percent of the total mass of particulate-phase PAHs analyzed. Also
present in indoor air in association with the use of smoky coal were the non-target compound

2Acenaphthene, acenaphthylene, anthracene, benz[a]anthracene, benzo[a]pyrene,
benzo[/)]fluoranthene, benzo[£]fluoranthene, benzo[g/z/]perylene, chrysene,
dibenz[a/z]anthracene, fluoranthene, fluorene, indeno[l,2,3-cd]pyrene, 2-methylnaphthalene,
naphthalene, phenanthrene, and pyrene.

Naphthalene and 2-methylnaphthalene, both two-ring PAHs, are among the 17 PAHs for
which routine monitoring is performed, but are not included in the scope of the current
assessment.

3Smoky coal is comparable to low sulfur (0.2%), medium volatile bituminous coal
(Mumford et al., 1999). Indoor air particles from smoky coal combustion contain mostly (51%)
submicron particles with approximately 80% organic content, including high concentrations
(43%) of the organic mass) of PAHs (Mumford et al., 1993).

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PAHs 5-methylchrysene, coronene, dibenzo[ae]pyrene, dibenzo[a/]pyrene, and
dibenz[ac]anthracene (Mumford et al., 1995). Review of monitoring data summarized by IPCS
(1998) indicates that anthanthrene (dibenzo[de//w2o]chrysene), benzo[e]pyrene, and coronene,
none of which are target compounds, are detected relatively frequently in air samples impacted
by various combustion sources (e.g., industrial emissions, vehicle emissions, indoor residential
heating, roofing operations).

EPA risk assessments of PAHs have focused on the target compound PAHs, which (with
one exception) are unsubstituted homocyclic PAHs. Alkylated PAHs (e.g., methylated PAHs),
however, may be important contributors to PAH risk. Chuang et al. (1992) reported that the
most bioreactive fraction from the PAH mixture from smoky coal combustion emissions (which
have been linked to human lung cancer) contained mainly alkylated PAHs and that these
alkylated PAHs were more bioactive in mutagenicity assays than the parent non-alkylated PAHs.
Animal studies have shown that methylated PAHs, e.g., dimethylbenz[c/]anthracene and 5-
methylchrysene, are more potent carcinogens than their parent compounds. Many nitrogen-
containing heterocyclic PAH compounds also coexist with PAHs in combustion emissions,
including coal combustion emissions and coke oven emissions. These compounds are known to
be carcinogenic in animals.

Further, various investigators have more recently identified highly bioactive PAHs for
which quantitative analytical determinations have not been historically performed. For example,
dibenzo[a/]pyrene (DB[a/]P) has been identified as one of the most potent PAH carcinogens
tested. Cavalieri et al. (1991) stated that "This compound has not been considered a very
important environmental carcinogen for two reasons. First, tumorigenicity tests before 1968
used the weakly active dibenzo[ae]fluoranthrene instead of DB[a/]P. Second, analytical data
quantitating its presence in cigarette smoke and other environmental hazards have not been
pursued until now." DB[a/]P has been detected in the combustion emissions of Tennessee coal
(Mumford et al., 1987) and in the ambient air near industrial emissions (IPCS, 1998). Review of
the extensive summary of PAH monitoring data in IPCS (1998), however, reveals relatively few
detections of DB[a/]P. Whether this apparent low detection frequency reflects a true low
frequency of occurrence of DB[a/]P in environmental emissions, or a failure to analyze for this
PAH, is unclear.

Waste site sampling shows the number of PAHs present in environmental media to be
substantially greater than the 17 PAHs on the TCL. ATSDR (1995) stated that 54 PAHs have
been identified at one or more National Priority List (NPL, or Superfund) hazardous waste sites.
The 54 PAHs include those PAHs on the TCL as well as other unsubstituted PAHs, 16
methylated PAHs, and nine heterocyclic PAHs containing atoms other than carbon and hydrogen
in their structure (e.g., sulfur, oxygen and nitrogen). Superfund's Contract Laboratory Program
(CLP) conducted an analysis of tentatively identified compounds (TICs) reported 10 or more

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times in soil matrix samples collected from 2/1/1995 through 12/31/2000 from predominantly
Superfund sites located across the country. Of 39,741 field samples evaluated, 16 homocyclic
PAHs not present on the TCL were identified. The number of occurrences for the 16 individual
PAHs ranged from 11 to 1,037. These PAHs identified only as TICs would not be routinely
included in site risk assessments.

Appendix A provides summary lists of PAHs for which routine monitoring is conducted
(i.e., PAHs on the TCL), PAHs reported as TICs at Superfund sites, and PAHs addressed in
health assessments undertaken by IRIS, California EPA, and other authoritative bodies (IPCS
and AT SDR).

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III. CURRENT EPA PRACTICES FOR ASSESSING PAH HEALTH RISK

A. Guidance Developed by EPA's Office of Research and Development (ORD)

1. Toxicity Assessments for Individual PAHs in IRIS

In the early 1990s, EPA's IRIS Program developed assessments for 15 PAHs.4 Of these
15, a quantitative cancer dose-response assessment was prepared for one carcinogenic PAH,
benzo[a]pyrene (B[a]P). Qualitative cancer weight-of-evidence (WOE) designations were
established for 14 of the 15 PAHs, and noncancer assessments for five PAHs. The cancer
assessments for the PAHs in IRIS are described further below.

Cancer WOE Evaluations

A WOE designation reflects a qualitative evaluation of the carcinogenicity data for a
chemical, and characterizes the likelihood, based on the available scientific data, that the
agent in question is a human carcinogen. Between 1990 and 1992, EPA assigned cancer
WOE designations of "D," not classifiable as to human carcinogenicity, to acenaphthylene,
anthracene, benzo[g/z/]perylene, fluoranthene, fluorene, phenanthrene, and pyrene. B[a]P,
benz[a]anthracene, benzo[/)]fluoranthene, benzo[£]fluoranthene, chrysene,
dibenz[a/z]anthracene, and indeno[l,2,3-cd]pyrene were classified as "B2," or probable
human carcinogens, based on sufficient evidence of carcinogenicity in animals, and
inadequate or no evidence in humans.

For all of the B2 carcinogens except B[a]P, the scientific data were considered
insufficient to develop quantitative estimates of carcinogenic potency.

B[a]P

In 1992, EPA derived an oral cancer slope factor for B[a]P of 7.3 (mg/kg/day)"1. This
estimate of carcinogenic potency was calculated as a geometric mean of four slope factors
derived from two bioassays, one in mice (Neal and Rigdon, 1967) and one in rats (Brune et
al., 1981). No estimate of cancer potency for B[a]P by inhalation was recommended by
EPA at that time. An inhalation cancer unit risk (UR) of 8 .8 x 10"4 (//g/m3)"1 had been
previously derived based on a bioassay in hamsters exposed to B[a]P condensed onto
aerosols of NaCl (Thyssen et al., 1981); however, consensus verification of this URby the
Carcinogen Risk Assessment Verification Endeavor (CRAVE) Workgroup (representative

4The IRIS database also includes an assessment for the two-ring PAH naphthalene. The
naphthalene assessment was updated in September 1998. Naphthalene is not included within the
scope of the current IRIS assessment for PAH mixtures.

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of Agency consensus until 1995) was not obtained. [Note: The California EPA used
Thyssen et al. (1981) as the basis for an inhalation UR of 1.1 x 10"3 (//g/m3)"1 (Cal EPA,
1999).]

The toxicity of B[a]P is currently being reassessed by the IRIS Program under the lead
of EPA's Office of Solid Waste and Emergency Response (OSWER).

A summary of the individual PAH assessments currently contained in the IRIS data
base is provided in Table 1 below.

TABLE 1

Summary of PAH Assessments Currently in IRIS

PAH
(CAS No.)

Cancer WOE
Classification

Quantitative Cancer Assessment
(Oral Slope Factor)3

Noncancer Assessment
(Oral Reference Dose)b

Acenaphthene
(83-32-9)

RfD = 0.06 mg/kg/day

Acenaphthylene
(208-96-8)

Anthracene
(120-12-7)

RfD = 0.3 mg/kg/day

Benz[a]anthracene
(56-55-3)

Bcnzo|fl|pyrcnc
(50-32-8)

SF = 7.3 (mg/kg/day)1

Benzo [/>]fluoranthene
(205-99-2)

Benzo [&]fluoranthene
(207-08-9)

Bcnzo|w/?/|pcrylcnc
(191-24-2)

Chrysene
(218-01-9)

Dibenz [ah\ anthracene
(53-70-3)

Fluoranthene
(206-44-0)

RfD = 0.04 mg/kg/day

Fluorene
(86-73-7)

RfD = 0.04 mg/kg/day

Indeno [ 1.2.3-«/|pyrcnc
(193-39-5)

Phenanthrene
(85-01-8)

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TABLE 1

Summary of PAH Assessments Currently in IRIS

PAH
(CAS No.)

Cancer WOE
Classification

Quantitative Cancer Assessment
(Oral Slope Factor)3

Noncancer Assessment
(Oral Reference Dose)b

Pyrene
(129-00-0)

RfD = 0.03 mg/kg/day

" A slope factor (SF) is a plausible upper-bound estimate of the probability of a response (cancer) per unit
intake of a chemical over a lifetime and is expressed as risk per mg/kg/day.

b A reference dose (RfD) is an estimate (with uncertainty spanning perhaps an order of magnitude) of a
daily exposure to the human population (including sensitive subgroups) that is likely to be without an
appreciable risk of deleterious effects during a lifetime. It is based on the assumption that thresholds exist
for certain toxic effects.

2. Assessments for PAH Mixtures

a. IRIS Toxicity Assessments for PAH-containing Mixtures

IRIS currently includes assessments for three PAH-containing mixtures: coke oven
emissions, creosote, and diesel emissions. A quantitative carcinogenicity assessment
has been performed only for coke oven emissions.

EPA's carcinogenicity assessment of coke oven emissions was conducted in 1984;
Agency-wide consensus of the assessment was obtained in 1989. EPA classified coke
oven emissions as an "A" (human) carcinogen, having concluded that there was
sufficient evidence of carcinogenicity in humans (based on studies in coke oven
workers showing increased risk of mortality from cancer of the lung, trachea and
bronchus, cancer of the kidney, cancer of the prostate, and cancer at all sites combined)
and in laboratory animals (based on studies of coke oven emission extracts and
condensates showing a carcinogenic response in inhalation studies and skin-painting
bioassays). EPA also derived an inhalation unit risk estimate for coke oven emissions
of 6.2 x 10"4 (/ig/day)"' (expressed as benzene-soluble organics extracted from the
particulate phase of coal tar pitch volatiles from coke oven emissions). This unit risk
was based on respiratory cancer in male coke oven workers.

b. Provisional Guidance for Oral Exposure to PAH Mixtures

In the early 1990s, EPA gave consideration to practices for estimating cancer risk
for exposure to PAH mixtures. The Office of Health and Environmental Assessment
(subsequently the National Center for Environmental Assessment) developed an
"estimated order of potential potency" (EOPP) for six PAHs classified as B2
carcinogens (probable human carcinogens) [Provisional Guidance for Quantitative Risk
Assessment ofPoly cyclic Aromatic Hydrocarbons (EPA, 1993)]. EOPPs are

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summarized in Table 2.

Specifically, EOPPs were developed for benz[a]anthracene, benzo[6]fluoranthene,
benzo [&]fluoranthene, chrysene, dibenz[c//?]anthracene, and indeno[l,2,3-cd]pyrene
relative to the potency of B[a]P. The values represent ratios that were calculated by
application of a form of the two-stage model of carcinogenesis (generally defaulting to
a one-stage model) to complete carcinogenesis assays in mouse skin, comparing the
point estimates to those for B[a]P tested at the same time, and rounding to orders of
magnitude. It was observed that the data for PAHs did not meet all the criteria for
development of a toxicity equivalence factor (TEF) approach as described by the Risk
Assessment Forum (e.g., demonstration of additivity, consistency of relative toxicity
across endpoints). Thus, EPA recommended that EOPPs be confined to use only for
cancer, a subset of PAHs (unsubstituted PAHs classified as B2 carcinogens), and
estimation of risk from oral exposure.

EOPPs provided in the 1993 Provisional Guidance are summarized below.

TABLE 2

Estimated Order of Potential Potencies (from EPA, 1993)

PAH (CAS No.)

EOPP

Bcnzo|fl|pyrcnc
(50-32-8)

B enz [a] anthracene
(56-55-3)

0.1

Benzo [/>]fluoranthene
(205-99-2)

0.1

Benzo [&]fluoranthene
(207-08-9)

0.01

Chrysene
(218-01-9)

0.001

Dibenz | ah | anthracene
(53-70-3)

1.0

Indeno [ 1.2.3-«/|pyrcnc
(193-39-5)

0.1

c. Guidance for Inhalation Exposure to PAH Mixtures

In 1993, the CRAVE Workgroup undertook the evaluation of inhalation cancer
risks for certain PAH-containing mixtures (diesel engine emissions, gasoline engine
emissions, aluminum smelter emissions, wood burning emissions, and polycyclic
organic matter (POM)). A comparative potency approach was considered for deriving

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quantitative estimates of inhalation cancer risk for POMs in various source categories.
(A description of the comparative potency approach is included in Section IV).
Agreement was not reached on either inhalation unit risks for the specific PAH-
containing mixtures or the use of the comparative potency approach for application to
various source categories. Other than the assessment for diesel emissions (EPA,
2000b), no attempts have been made by the Agency to estimate cancer potency via
inhalation for PAH-containing mixtures.

B. Current Practices within EPA Program Offices

Program offices within EPA have regulatory responsibility for PAHs present in different
environmental media and from various sources. The Office of Air and Radiation (OAR) deals
largely with PAHs present in emissions to the air from various industrial processes (e.g., the
production of coal tar and coke, petroleum catalytic cracking), incomplete combustion (e.g.,
incinerators), or diffuse sources such as motor vehicles. According to ATSDR (1995), stationary
sources account for approximately 80% of total annual PAH emissions, and mobile sources
account for the remainder. The PAH composition of these emissions is largely a function of the
combustion source and, in some instances, the emissions at the source may differ from the PAH
profile found at the site of exposure.

PAHs present in soil and sediment may be associated with a variety of sources, including
atmospheric deposition after either local or long-range transport, disposal of sludge from public
sewage treatment plants, automobile exhaust, leachate from bituminous coal storage sites,
releases from creosote production, wood-preserving, and coking plants, and residues from
former manufactured gas plants (ATSDR, 1995). Because of partitioning and weathering (i.e.,
changes in composition due to microbial degradation, photolysis, hydrolysis, and oxidation) and
difficulties in associating current contamination with historical sources of contamination, PAHs
in soil and sediments are less readily characterized in terms of emissions source category.

How an EPA program office addresses PAH health risk for media or sources for which it
has regulatory authority is in large part a function of the type of monitoring data collected for
that regulated medium or source. A brief description of regulatory practices in OAR and
OSWER-two offices that have requested an IRIS assessment for PAH mixtures-follows.

1. Office of Air and Radiation

PAHs fall within the Clean Air Act listed hazardous air pollutant group, polycyclic
organic matter (POM).5 Accordingly, OAR hazardous air pollutant risk assessment
activities routinely include PAHs. Two current OAR activities that assess PAH risk include:

5POM includes organic compounds with more than one benzene ring, and which have a
boiling point greater than or equal to 100°C.

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(1) the assessment of risk remaining (i.e., residual risk per CAA 112(f)) from air emissions
of the hazardous air pollutant source categories following the implementation of control
technologies (e.g., maximum achievable control technology, "MACT") (USEPA, 1999), and

(2) the cumulative risk assessment performed as part of the National-Scale Assessment for
the 1996 base year (USEPA, 2001). The former activity encompasses oral and inhalation
exposure pathways, while limitations in national scale modeling tools have limited the latter
to inhalation only. Exposure estimates are primarily based on modeling estimates due to
scarce air monitoring data for PAHs.

In the source category specific risk assessments performed for the residual risk
program, inhalation and ingestion exposures to emitted PAHs have been assessed using
currently available cancer dose-response information (e.g., cancer weight of evidence and
unit risk estimates and relative potency factors from IRIS and California EPA) in a
cumulative manner. For the National-Scale Assessment, consideration of PAHs was limited
by a near total lack of speciated emissions data. OAR was obliged to use generic PAH
profiles for a few large emissions sources and apply them to all areas of the country. These
generic profiles were assigned unit risk estimates based on dose-response assessments
developed by California EPA for seven carcinogenic PAHs.

Current OAR assessments for POM are driven by the PAH component, and with regard
to cancer risk assessment, by the seven PAHs identified by EPA as probable human
carcinogens.

2. Office of Solid Waste and Emergency Response (OSWER)

EPA's Superfund Program, within OSWER, is charged with cleaning up the nation's
uncontrolled hazardous waste sites. Under this program, EPA evaluates potential health
risks associated with site-related contaminants present in contaminated media, via various
pathways of potential exposure. For PAHs, this may involve consideration of exposures to
contaminated media via ingestion, inhalation and dermal contact. Risks are based on
analytical data or modeled concentrations for target compounds in soil, sediment, surface
water, ground water, and air. Among these target compounds are the 17 individual PAHs on
Superfund's Target Compound List.

Most EPA regional offices limit their evaluation of PAHs to risks associated with
ingestion of the seven carcinogenic PAHs included in EPA's 1993 provisional guidance for
PAHs. Some regions additionally include evaluation of potential carcinogenic risk
associated with inhalation exposure using the inhalation unit risk that was initially proposed
by the CRAVE workgroup in 1994 but was not finalized. A few regions have also
attempted to quantify risks associated with dermal contact with PAH-containing
soil/sediment. Guidance on dermal assessment for PAHs is limited to the following
language from EPA's Risk Assessment Guidance for Superfund (EPA, 1989):

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It is inappropriate to use the oral slope factor to evaluate the risks
associated with dermal exposure to carcinogens such as benz(a)pyrene,
which cause skin cancer through a direct action at the point of
application... Generally only a qualitative assessment of risks from dermal
exposure to these chemicals is possible.

As indicated above, the profile of PAHs in soil and sediment is typically not
representative of the original PAH source. Unlike OAR, characterization of the health risk
for a sample containing PAHs based on source category is less likely to be a useful approach
for the situations addressed under the Superfund Program.

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IV. APPROACHES TO HEALTH ASSESSMENT FOR PAH MIXTURES

A. Introduction

The Risk Assessment Forum recently published Supplementary Guidance for Conducting
Health Risk Assessment of Chemical Mixtures ("Mixtures Guidance") (EPA, 2000a), as a
supplement to the Agency's 1986 Guidelines for the Health Risk Assessment of Chemical
Mixtures (EPA, 1986). This guidance will be used as a framework for organizing and presenting
the methods that have applicability to PAH mixtures.

The Mixtures Guidance describes assessment procedures using data on the mixture of
interest, data on toxicologically similar mixtures, and data on the mixture component chemicals.
The guidance is intended to assist the risk assessor in selecting an appropriate mixtures method,
beginning with an assessment of data quality, followed by evaluation of the type of data
available. As noted in the Mixtures Guidance, "The major concerns for the user are whether the
available data are on components or whole mixtures, whether the data are composed of either
similar components or similar mixtures that can be thought of as acting by similar toxicologic
processes, and whether the data may be grouped by emissions source, chemical structure, or
biologic activity."

The preferred approach to the health risk evaluation of chemical mixtures is an assessment
using health effects and exposure data on the whole mixture. Whole mixtures data can be
divided into the following subsets: data directly on the mixture of interest, data on a sufficiently
similar mixture, and data on a group of similar mixtures. If data are not available for a
reasonably similar mixture, an assessment may be based on the toxic or carcinogenic properties
of the components in the mixture. A relative potency factor approach is one type of components
approach that can be applied when the components are toxicologically similar.

EPA has prepared dose-response assessments for several whole PAH-containing mixtures,
including coke oven emissions (cancer assessment) and diesel emissions (noncancer
assessment). Because the number of PAH-containing mixtures with adequate dose-response data
is limited, a whole mixtures approach that uses only data directly on the mixture of interest can
not begin to address the large number of diverse PAH-containing mixtures to which exposure
may occur. Therefore, various approaches to the evaluation of the health risk of PAH mixtures
that can be applied to a diversity of PAH-containing mixtures have been proposed. Because
information on the noncancer effects of PAHs is limited, existing approaches are based on the
assessment of potential carcinogenic risk posed by PAH mixtures. Those approaches that appear
to have some practical application to the situations addressed by EPA program offices are the
following: (1) surrogate approach (based on data for similar mixtures), (2) comparative potency
approach (based on data for a group of similar mixtures), and (3) relative potency factor
approach (based on component PAHs). Basic features of each are briefly summarized below and

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in Table 3. More complete discussions of each approach, including principles and assumptions,
validation, existing applications, and advantages and disadvantages, appear in IPCS (1998) and
Schoeny et al. (1998).

TABLE 3

Summary of Major Features of Existing PAH Assessment Approaches

Feature

Surrogate Approach

Comparative
Potency Approach

Relative Potency Factor
Approach

Whole mixture vs.
component approach?

whole mixture
approach

component approach

Estimates the potency of
the whole mixture or the
PAH component of the
mixture?

PAH component of
the whole mixture

whole mixture

Selected PAHs only
(specifically those
analyzed and for which
RPFs are available)

Type of study from which
dose-response assessment
is obtained

Dose-response data
for a whole mixture,
preferably for a
mixture whose
carcinogenic potency
is largely attributable
to its PAH component

Human epidemiologic
data and bioassay data
(e.g., mouse skin
tumor initiation assay)
for a set of similar
mixtures from which a
scaling factor is
derived

Bioassay data for the index
PAH (e.g, B[a]P)

How are interactions
handled?

Interactions are addressed implicitly; knowledge
of specific interactions (synergism, antagonism,
additivity) among PAHs is unnecessary

Assumes dose additivity

Data required to apply
approach to mixture of
interest

(1) Data
demonstrating
"sufficient similarity"
to mixture with dose-
response data

(2) Concentration of
surrogate PAH (e.g.,
B[a]P)

(1) Data
demonstrating
"sufficient similarity"
to set of mixtures used
to derive scaling
factor

(2) Bioassay data for
the mixture of interest
(e.g., mouse skin
tumor initiation data)

Data on concentrations of
component PAHs

B. Surrogate Approach (Using Data for Sufficiently Similar Mixtures)

The Mixtures Guidance (Section 3.1.2) states that:

If adequate data are not available on the mixture of concern, but health
effects data are available on a similar mixture, a decision should be made
whether the mixture on which health effects data are available is or is not
"sufficiently similar" to the mixture of concern to permit a risk assessment.

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The determination of "sufficient similarity" should be made on a case-by-case
basis, considering not only the uncertainties associated with using data on a
surrogate mixture, but also contrasting the inherent uncertainties if one were to
use other approaches, such as component-based approaches.

Strategies for a PAH mixtures assessment involving the use of a surrogate PAH have been
proposed that are premised on similarity of the mixture of interest to another mixture with a
more complete toxicity data base. Two applications of the surrogate approach are considered
here.

The surrogate approach assumes that the risk associated with the PAH component of
complex mixtures is proportional to the level of an index or surrogate chemical (typically B[a]P)
in the mixture, given a similar relative composition of individual PAHs in the various mixtures.
Given this proportionality, the potency of a PAH mixture of interest can be predicted from
information on the level of B[a]P (or some other surrogate PAH) in that mixture and an estimate
of the cancer potency for a similar PAH mixture (expressed as risk per unit amount of B[a]P or
other surrogate). As stated in IPCS (1998), this approach, in general, does not predict the
potency of an ambient complex mixture as a whole but just its PAH component. Because, for
example, B[a]P does not serve as a reliable general indicator of all pollutants in a complex
mixture, the contribution of the non-PAH components to the overall risk of exposure to a
complex mixture must be assessed separately.

The most extensive examination of PAH profiles of complex mixtures and the use of B[a]P
as a surrogate for the PAH component of mixtures was conducted by the Ontario Ministry of the
Environment (OMOE, 1997). A summary of the OMOE report is provided in IPCS (1998) and
Schoeny et al. (1998).

The starting point in applying this approach is to estimate carcinogenic potency (e.g., the
inhalation unit risk, "UR") associated with a typical PAH mixture. Based on information on the
B[a]P content of that mixture, potency is expressed as risk per unit amount of B[a]P (e.g., risk
per ng B[a]P/m3 air). This potency estimate is used for subsequent assessments of other PAH
mixtures of unknown carcinogenic potency. For example, OMOE (1997) proposed a cancer
potency estimate of 2.3 x 10"5 (ng BfaJP/m3)"1 using the EPA's assessment of lung cancer risk in
coke oven workers. The next step is to estimate the level of B[a]P in the environmental mixture
of interest. The risk associated with the PAH component of the mixture of interest can be
estimated as:

Risk = B[a]P Cone, in Environmental Mixture x
(e.g., ngB[a]P/m3)

Carcinogenic Potential of Typical PAH Mixture
Expressed per Unit Amount ofB[a]P
(e.g., risk per ng B[a]P/m3)

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Dr. Gary Foureman of EPA's National Center for Environmental Assessment and Dr. Roy
Smith of EPA's Office of Air Quality Planning and Standards developed a similar approach for
assessing the health risk of PAH mixtures in air using data for a sufficiently similar PAH mixture
that also includes a procedure for evaluating whether or not differences in composition are likely
to be toxicologically significant. The approach assumes that all PAH-containing mixtures in air
are essentially the same as a mixture of coal tar pitch (CTP), a PAH mixture of known
composition and carcinogenic potency, and that the concentrations of B[a]P and other detected
airborne PAHs are simply dilutions of CTP. Other information, including an inhalation unit risk
derived for CTP, is used in conjunction with actual exposure information in making a judgment
on use of this approach. This application of a surrogate approach using data for sufficiently
similar mixtures is presented in Foureman and Smith (1999) and is summarized in Appendix B.

C. Comparative Potency Approach (Based on Data for a Group of Similar Mixtures)

In some cases, data are available on a group of similar mixtures. A procedure developed for
environmental mixtures that applies data for similar mixtures is the comparative potency
approach. In this procedure, a set of mixtures of highly similar composition is used to estimate
a scaling factor that relates the toxic potency of a mixture in one assay to the potency in a second
assay of the same toxic endpoint. The mixture of interest can then be tested in one of the assays
(preferably a relatively simple, low-cost assay), and the resulting potency can be adjusted by the
scaling factor to estimate the potency in the second assay (preferably an "assay" which
constitutes human data). The comparative potency approach is used to estimate the potency of a
PAH-containing mixture without having to identify or quantify individual PAH compounds.

This approach rests on the assumption that the similar mixtures in a set act in a similar
manner toxicologically, and that for all members of the group of similar mixtures there exists a
constant linear relationship between the potencies derived from the two assays. Where the data
sets for a group of similar mixtures consist of data from an experimental assay and from human
epidemiological studies, the relationship can be shown as follows:

Human cancer potencymjxture x Human cancer potencymjxture 2
Bioassay potency mixture x Bioassay potency mixture 2

For a mixture of interest ("mixture A") that is considered to be a member of the group of similar
mixtures and for which appropriate bioassay data exist, human cancer potency can be estimated
by rearranging the above equation as follows:

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Human cancer potencymixtureA = Bioassay potencymixtureA x k

This approach was originally developed as the basis for estimating the human lung cancer
unit risk for the polycyclic organic matter (POM) associated with diesel emissions (Albert et al.,
1983). Measures of comparative potency were derived from data for the complex POM
emissions from coke ovens, roofing tar, and cigarette smoke (Albert et al., 1983; Lewtas, 1985,
1991; Nesnow, 1990).6 These three combustion-related mixtures were ones that had human data
sufficient to derive a human cancer unit risk estimate and that had been tested in the Senear
mouse skin tumor initiation assay. Based on the relationship between human lung cancer risk
and potency in the mouse skin tumor initiation assay, a scaling factor ("k") could be derived.

This approach can be used to estimate cancer potency for other PAH-containing mixtures -
after making a weight of evidence (WOE) determination that the mixture is a potential human
carcinogen and a demonstration of sufficient similarity to the set of mixtures used to develop the
scaling factor.

Further description of this approach is provided in Nesnow (1990) and in Section 3.3.2.3 of
the Mixtures Guidance.

D. Relative Potency Factor Approach (Component Approach)

Unlike the first two approaches presented in this section that rely on dose-response data for
whole mixtures, the relative potency factor (RPF) approach is based on an evaluation of
individual components of the mixture. The premise of this approach is that the health effects of
a mixture of related chemical compounds can be estimated as the sum of the effects of the
individual components of the mixture. The approach relies on both the existence of
toxicological dose-response data for at least one component of the mixture (referred to as the
index compound) and scientific judgment about the toxicity of the other individual compounds in
the mixture relative to the index compound. The RPF methodology is described in the Mixtures
Guidance (Section 4.4.1) as follows:

The toxicity of the related compounds is predicted from the index compound
by scaling the exposure level of each compound by its toxicity relative to the
index compound. This scaling factor or proportionality constant is based on an
evaluation of the results of a (usually) small set of toxicologic assays or
analyses of the chemical structures. This constant is call the RPF and

6The coke oven unit risk estimate was reviewed and verified by EPA's CRAVE work
group in 1989. The inhalation potency estimates based on human data for roofing tar and
cigarette smoke have not undergone an EPA review similar to that for coke oven emissions, and
do not represent Agency consensus values.

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represents the relative toxicity with respect to the index compound. For
example, if compound A is judged to be one-tenth as toxic as the index
compound, i.e., it requires ten times the exposure to cause the same toxicity,
then the RPF for compound A is 0.1. If all components of the mixture are
assumed to be as toxic as the index compound, then all of the RPFs would be
1.0; conversely, if all of the related compounds have negligible toxicity, all of
their RPFs could be assigned a value of 0.

In the RPF approach, an exposure equivalent to the index compound is the
product of the measured concentration of the mixture component and the RPF.

These dose equivalents are summed to express the mixture exposure in terms
of an equivalent exposure to the index compound; risk can be quantified by
comparing the mixture's equivalent dose in terms of the index compound to
the dose-response assessment of the index compound.

Mathematically, the procedure can be expressed as follows, where Cm is the mixture
concentration expressed as index compound; Ck is the concentration of the kth mixture
component; and RPFk is the proportionality constant for toxicity of the kth mixture component
relative to the toxicity of the index compound:

C„ = 'LC„xRPFi

k=1

Various strategies for evaluating PAH health risk using a relative potency factor approach
have been developed. Seven such schemes, all of which use B[a]P as the index chemical, are
described in IPCS (1998) and Schoeny et al. (1998). The relative potency factor paradigm
adopted in EPA's 1993 Provisional Guidance, which is applied in most assessments of PAH
health risk by EPA, was described in a previous section.

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V. CHARGE QUESTIONS

EPA's IRIS Program intends to develop an approach (or approaches) to assessing the cancer
risk posed by environmental mixtures of PAHs. The ideal situation, but one infrequently
supported by the available data, is to base the health risk evaluation of a PAH mixture on dose-
response and exposure data for that whole mixture. EPA is interested in developing guidance
for those situations when health effects data for the specific PAH-mixture of interest are not
available. EPA has reviewed existing approaches to the assessment of cancer risk from exposure
to PAH mixtures. The principal approaches are the surrogate approach (based on similar
mixtures), comparative potency approach (based on sets of similar mixtures), and relative
potency factor approach (based on analysis of component PAHs). Summaries of the approaches
are provided in Section IV. EPA recognizes that each approach has certain limitations and that
each may have varying applicability to the program offices that regulate PAHs from different
sources and environmental media, and use different types of monitoring data. For example, a
whole-mixtures approach based on dose-response data for a specific PAH-containing mixture
may not be useful in evaluating the health risk associated with soil samples containing PAHs
from unknown (or possibly multiple) sources.

Thus, in evaluating the alternative approaches to the cancer assessment of PAH mixtures,
workshop participants might wish to consider the following:

the scientific merits of each approach, and recommendations for revising the
approaches consistent with the available toxicological literature; and
the applicability of each approach for different exposure situations of interest to EPA
(e.g., PAHs present in stack emissions from various industrial processes or incomplete
combustion sources, PAHs present in emissions to air from diffuse sources such as
motor vehicles, or PAHs present in soils or sediments associated with releases from
various industrial processes (e.g., wood-preserving operations, coking plants) or
atmospheric deposition).

A. Surrogate Approach (Using Data for Sufficiently Similar Mixtures)

The surrogate approach assumes that the cancer risk associated with the PAH component of
complex mixtures is proportional to the level of a surrogate PAH (typically B[a]P) in the
mixture, and that this assumption holds for mixtures with a similar relative composition of
component PAHs. Given this proportionality, the potency of a PAH mixture of interest can be
predicted from information on the level of the surrogate (e.g., B[a]P) in that mixture and an
estimate of the cancer potency for a similar mixture (expressed as risk per unit amount of
surrogate PAH). Two applications of the surrogate approach - OMOE (1997) and Foureman and

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Smith (1999) - were presented in Section IV.

Workshop participants may wish to consider the following questions in their deliberations
concerning this approach.

1. What are the important issues to consider in developing an application of this approach? In
particular, what are important considerations in judging whether a PAH mixture is "sufficiently
similar" to a mixture for which dose-response data are available? (e.g., analysis of component
PAHs; source categories; stratification by different combinations of fuel type and combustion
technology; response in assays of carcinogenic potency; environmental fate resulting in
"weathering").

2. The surrogate approach is intended to characterize risk associated with the PAH component
of a complex "sufficiently similar" mixture - not the whole mixture (since no one surrogate PAH
can be an indicator for non-PAH components of a complex mixture). Of the available
epidemiologic and experimental animal data sets, which toxicity data set (or sets) is (are) most
appropriate for estimating the cancer potency of a PAH mixture? Which would not be
appropriate?

3. What are some of the limitations that must be recognized in applying this approach? Are
there clear examples of when this approach is or is not applicable?

4. Is there a surrogate that can be viewed as appropriate for all carcinogenic PAHs? For a subset
of PAHs (e.g., 4- to 7-ring unsubstituted PAHs) only? Rather than a single PAH, is there a
group of key PAHs responsible for the majority of toxicity (e.g., PAHs with four or more rings,
methylated PAHs) that might be scientifically preferable for use as a surrogate?

5. For what kinds of exposures is this approach applicable? For which situations, taking both
exposure and data availability into account, could it be considered the preferred (or only viable)
approach?

B. Comparative Potency Approach (Based on Data for a Group of Similar Mixtures)

The comparative potency approach assumes that the relative potency of two carcinogens (or
mixtures) in one bioassay system is directly proportional to the relative potency in a second
bioassay system (where ideally, one "bioassay" constitutes human data). This assumption was
specifically examined for three complex organic emission products from coke ovens, roofing tar
and cigarettes, all three of which are PAH-containing mixtures and known human lung
carcinogens. For these three emission products, the relative potencies in the mouse skin tumor
initiation assay were (within a factor of two) directly proportional to the relative potencies

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estimated for these emissions from human lung cancer epidemiological data. From this
empirical relationship, a scaling factor can be developed that relates potency in the animal
bioassay to human cancer risk. A PAH-containing mixture without epidemiological data can be
tested in bioassay systems (e.g., mouse skin tumor initiation assay, mouse lymphoma assay,
Ames bioassay, etc.), and the resulting potency can be adjusted by the scaling factor to estimate
the potency in humans.

Workshop participants may wish to consider the following points in their deliberations
concerning this approach.

1. What are the important issues to consider in developing an application of this approach?

2. How widely applicable is this approach?

3. Are there potential alternatives to the mouse skin tumor initiation assay to use in developing
scaling factors?

4. Is it appropriate to relate the response of a PAH-containing mixture in the mouse skin tumor
initiation assay to human cancer risk via inhalation and oral exposure? Can we use mouse skin
data and PBPK models to extrapolate to inhalation and oral routes of exposure?

5. Are there other examples of complex mixtures that could be used to expand the original data
set (cigarette smoke, roofing tar emissions, and coke oven emissions)?

6. For what kinds of exposures is this approach applicable? For which situations, taking both
exposure and data availability into account, could it be considered the preferred (or only viable)
approach?

C. Relative Potency Factor Approach (Component Approach)

Unlike the two approaches considered above that are based on data for whole mixtures, the
relative potency factor (RPF) approach is based on data for individual components of the
mixture. Carcinogenic potency is calculated for the index PAH, typically B[a]P, and the toxicity
of related PAHs in the mixture is predicted from the index PAH by scaling the exposure level of
each PAH by its toxicity relative to the index PAH. Dose equivalents are summed to express the
mixture exposure in terms of an equivalent exposure to the index PAH.

EPA's 1993 Provisional Guidance, which is the principal method used by EPA program and
regional offices to characterize potential PAH cancer risk for PAHs in various media or for
PAHs from mixed sources, is an example of the RPF (component) approach.

Workshop participants may wish to consider the following points in their deliberations

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concerning this approach.

1. What are the important issues to consider in developing an application of this approach?

2. What are important factors to consider in determining which PAHs to include in a RPF
scheme? (e.g., weight-of-evidence (WOE) of carcinogenicity; chemical structure (QSAR);
mode/mechanism of action; availability of certain types of studies, such as in vivo cancer
bioassays, etc.)7

3. Should a RPF scheme take into account evidence that PAHs appear to induce different types
of DNA damage via more than one mode of action? If so, how can this be accomplished?

4. B[a]P has traditionally been used as the "index" PAH to which the tumorigenic potency of
other PAHs has been related. Does the current science support the continued use of B[a]P as the
index for all exposure routes, especially in the context of the more newly discovered highly
potent species of PAHs? If so, what data should be used to establish a cancer slope factor (SF)
for B[a]P by the oral route? By the inhalation route? By the dermal route?

5. A RPF approach requires that data from a certain assay or assays be used to establish the
potency of one PAH relative to another. For example, in developing relative potency estimates,
Thorslund & Farrah (1990) relied on data from lung implants in rodents, and to a much lesser
extent, complete carcinogenesis in mouse skin. EPA interim relative potency factors are based
on skin painting results (EPA, 1993). What about the AJ mouse cancer model of Nesnow and
Ross? Goldstein et al. (1998) recommended that lung tumor incidence be used as the most
appropriate basis for quantitative risk assessment of coal tars. Which assay systems (including
whole animal, in vitro) are most relevant for developing RPFs? Should a "joint analysis," where
data sets are combined, be attempted?

6. What are the limitations associated with developing one set of RPFs for all three routes of
exposure (i.e., inhalation, oral, and dermal)? What are important considerations in developing
RPFs for each route?

7Note: EPA's 1993 Provisional Guidance developed RPFs for seven PAHs only. These
RPFs were limited to unsubstituted PAHs with three or more fused aromatic rings that were
classified by EPA as probable human carcinogens (B2 carcinogens) based on sufficient data
from animal bioassays; substituted PAHs and PAHs with elements other than carbon and
hydrogen in their composition were excluded. OMOE, in contrast, developed RPFs for over 200
PAHs.

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7. EPA's Provisional Guidance (EPA, 1993) adopted the assumption that the carcinogenicity of
individual PAHs is additive. Is the default assumption of dose additivity supported by the
current science?

8. For what kinds of exposures is this approach applicable? For which situations, taking both
exposure and data availability into account, could it be considered the preferred (or only viable)
approach?

D. General Questions

1. EPA's objective is to develop a scientifically supportable approach (or approaches) for
assessing the health risk of PAH mixtures that will be useful to EPA program offices. Are there
approaches other than the three presented above that should be considered?

2. What is the most appropriate approach for:

a. PAHs in various media (i.e., soils, sediments, ground water, surface water or air)
associated with a known source (e.g., residues from former manufactured gas plants,
creosote production, or sludge from public sewage treatment plants)?

b. PAHs in various media from mixed or unknown sources?

c. PAHs in various media that were subject to partitioning and weathering?

d. PAHs in air as a result of emissions from various industrial processes (e.g., the
production of coal tar and coke, petroleum catalytic cracking) or incomplete combustion
sources (e.g., incinerators)?

e. PAHs in air as a result of emissions from a diffuse source such as motor vehicles?

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REFERENCES

Agency for Toxic Substances and Disease Registry (ATSDR). 1995. Toxicological profile for
polycyclic aromatic hydrocarbons (PAHs) (Update).
http://www.atsdr.cdc.gov/toxprofiles/tp69.html

Albert, R.E., J. Lewtas, S. Nesnow, T.W. Thorsland, and E. Anderson. 1983. Comparative
potency method for cancer risk assessment: application to diesel particulate emissions. Risk
Anal. 3:101-117.

Brune, H., R.P. Deutsch-Wenzel, M. Habs, S. Ivankovic, andD. Schmahl. 1981. Investigation of
the tumorigenic response to benzo[a]pyrene in aqueous caffeine solution applied orally to
Sprague-Dawley rats. J. Cancer Res. Clin. Oncol. 102:153-157.

California Environmental Protection Agency (Cal EPA). 1999. Air Toxics Hot Spots Program
Risk Assessment Guidelines. Part II. Technical Support Document for Describing Available
Cancer Potency Factors. Office of Environmental Health Hazard Assessment, Air Toxicology
and Epidemiology Section. April. http://www.oehha.org/pdf/HSCA2.pdf

Cavalieri, E.L., S. Higginbotham, N.V.S. RamaKrishna, P.D. Devanesan, R. Todorovic, E.G.
Rogan, and S. Salmasi. 1991. Comparative dose-response tumorigenicity studies of
dibenzo[a,l]pyrene versus 7,12-dimethylbenz[a]anthracene, benzo[a]pyrene and two
dibenzo[a,l]pyrene dihydrodiols in mouse skin and rat mammary gland. Carcinogenesis
12:1939-44.

Chuang, J.C., S.A. Wise, S. Cao, and J.L. Mumford. 1992. Chemical characterization of
mutagenic fractions of particles from indoor coal combustion: A study of lung cancer in Xuan
Wei, China. Environmental Sci. Technol. 26:999-1004.

Foureman, G.L., and R.L. Smith. 1999. A proposed procedure for derivation of regulatory
values for carcinogenic airborne polycyclic aromatic hydrocarbons (PAHs) based on coal tar
pitch (CTP) volatiles. Air and Waste Management Association Proceedings 1999 (Paper 99-
259).

Goldstein, L.S., E.H. Weyand, S. Safe, M. Steinberg, S.J. Culp, D.W. Gaylor, F.A. Beland, and
L.V. Rodriguez. 1998. Tumors and DNA adducts in mice exposed to benzo[a]pyrene and coal
tars: implications for risk assessment. Environ. Health Perspect. 106:1325-1330.

International Programme on Chemical Safety (IPCS). 1998. Environmental Health Criteria 202.
Selected non-heterocyclic polycyclic aromatic hydrocarbons. Appendix I. Some approaches to
risk assessment for polycyclic aromatic hydrocarbons.
http://www.inchem.org/documents/ehc/ehc/ehc202.htm

Lewtas, J. 1985. Development of a comparative potency method for cancer risk assessment of
complex mixtures using short-term in vivo and in vitro bioassays. Toxicol. Indiist. Health 1:193-
203.

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Lewtas, J. 1991. Carcinogenic risks of polycyclic organic matter (POM) from selected emission
sources. Development of a comparative potency method. Deliverable Report No. 3128. February
28. HERL Report #0803.

Mumford, J.L., X.Z. He, R.S. Chapman, S.R. Cao, D.B. Harris, X.M. Li, Y.L. Xian, W.Z. Jiang,
C.W. Xu, J.C. Chuang, W.E. Wilson, and M. Cooke. 1987. Lung cancer and indoor air pollution
in Xuan Wei, China. Science 235:217-220.

Mumford, J.L., R.W. Williams, D.B. Walsh, R.M. Burton, D.J. Svendsgaard, J.C. Chuang, V.S.
Houk, and J. Lewtas. 1991. Indoor air pollutants from unvented kerosene heater emissions in
mobile homes: studies on particles, semivolatile organics, carbon monoxide, and mutagenicity.
Environ. Sci. Technol. 25:1732-38.

Mumford, J.L., X. Lee, J. Lewtas, T.L. Young, and R.M. Santella. 1993. DNA adducts as
biomarkers for assessing exposure to polycyclic aromatic hydrocarbons in tissues from Xuan
Wei women with high exposure to coal combustion emissions and high lung cancer mortality.
Environ. Health Persp. 99:83-87.

Mumford, J.L., X. Li, F. Hu, X.B. Lu, and J.C. Chuang. 1995. Human exposure and dosimetry of
polycyclic aromatic hydrocarbons in urine from Xuan Wei, China with high lung cancer
mortality associated with exposure to unvented coal smoke. Carcinogenesis 16:3031-36.

Mumford, J.L., D. Tian, M. Younes, F. Hu, Q. Lan, M.L. Ostrowski, X. He, and Z. Feng. 1999.
Detection of p53 protein accumulation in sputum and lung adenocarcinoma associated with
indoor exposure to unvented coal smoke in China. Anticancer Research 19:951-58.

Neal, J., and R.H. Rigdon. 1967. Gastric tumors in mice fed benzo(a)pyrene: A quantitative
study. Tex. Rep. Biol. Med. 25:553-557.

Nesnow, S. 1990. Mouse skin tumours and human lung cancer: Relationships with complex
environmental emissions. In: Vanio, H., M. Sorsa, and A.J. McMichael, eds. Complex Mixtures
and Cancer Risk. IARC Scientific Publication No. 104. Lyon: International Agency for Research
on Cancer. Pp. 44-54.

Ontario Ministry of the Environment and Energy. 1997. Scientific criteria document for
multimedia standards development: Polycyclic aromatic hydrocarbons (PAH). Part 1. Hazard
identification and dose-response assessment. ISBN 0-7778-5914-9.

Shoeny, R., P. Muller, and J.L. Mumford. 1998. Risk assessment for human health protection -
Applications to environmental mixtures. In: Douben, P.E.T., ed. Pollution Risk Assessment and
Management. Chichester: John Wiley & Sons Ltd.

Thorslund, T.W., and D. Farrah. 1990. Development of relative potency estimates for PAHs and
hydrocarbon combustion product fractions compared to benzo[a]pyrene and their use in
carcinogenic risk assessments. Draft. Prepared by Clement International Corporation. Prepared
for U.S. EPA. September 30, 1990.

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Thyssen, J., J. Althoff, G. Kimmerle, and U. Mohr. 1981. Inhalation studies with benz[a]pyrene
in Syrian golden hamsters. J. Natl. Cancer Inst. 66:575-577.

U.S. Environmental Protection Agency (EPA). 1986. Guidelines for the health risk assessment of
chemical mixtures. Fed. Reg. 51:34014-25. September 24.

U.S. Environmental Protection Agency (EPA). 1989. Risk Assessment Guidance for Superfund.
Volume I. Human Health Evaluation Manual (Part A). Interim final. Office of Emergency and
Remedial Response, Washington, D.C. EPA/540/1-89/002.

U.S. Environmental Protection Agency (EPA). 1993. Provisional Guidance for Quantitative Risk
Assessment of Poly cyclic Aromatic Hydrocarbons. Office of Research and Development.
EPA/600/R-93/089.

U.S. Environmental Protection Agency (EPA), Office of Air Quality Planning and Standards.
1999. Residual Risk Report to Congress. EPA-453/R-99-001. March.
http://www.epa.gov/ttncaaal/t3/reports/risk rep.pdf

U.S. Environmental Protection Agency (EPA). 2000a. Supplementary Guidance for Conducting
Health Risk Assessment of Chemical Mixtures. EPA/630/R-00/002. August.
http://www.epa.gov/ncea/raf/chem mix.htm

U.S. Environmental Protection Agency (EPA). 2000b. Health Assessment Document for Diesel
Exhaust. EPA/600/8-90/057E. July. SAB Review Draft, http://www.epa.gov/ncea/dieslexh.htm

U.S. Environmental Protection Agency (EPA). 2001. National-Scale Air Toxics Assessment for
1996. Office of Air Quality Planning and Standards. EPA-453/R-01-003. January. SAB Review
Draft, http://www.epa. gov/ttn/atw/sab/sabrev.html#A1

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APPENDICES

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APPENDIX A

PAHs Included on Selected Monitoring and Assessment Lists

PAH

CAS No.

IRIS

(a)

Cal
EPA

(b)

WHO

EHC
(1998)
(c)

ATSDR

Tox.
Profile

(1995) (d)

TCL
(Priority
Pollutant)
List (e)

Superfund
Site TIC

(f)

Acenaphthene

83-32-9

Acenaphthylene

208-96-8

Anthanthrene
(dibenzo [defmno]
chrysene)

191-26-4

Anthracene

120-12-7

Benzo [a]fluorene

238-84-6

Benzo [a]pyrene

50-32-8

Benzo [/>]fluoranthene

205-99-2

Benzo [6]fluorene

243-17-4

Benzo [cjphenanthrene

195-19-7

Benzo [ejpyrene

192-97-2

Benzo [g/z/']fluoranthene

203-12-3

Bcn/o |w/?/|pcnlcnc

191-24-2

Benzo [/]fluoranthene

205-82-3

Benzo [&]fluoranthene

207-08-9

B enz [a] anthracene

56-55-3

B enz [a] anthracene,
7,12-dimethyl-

57-97-6

Chrysene

218-01-9

Chrysene, 5-methyl

3697-24-3

Coronene

191-07-1

Cy c lope nta | cd\py re ne

27208-37-3

Cyclopentalcfe/]
phenanthrene, C2-4H-

Cyclopentalcfe/]
phenanthrene, C3-4H-

Cyclopentalcfe/]
phenanthrene, C4-4H-

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A-l

DISCUSSION DOCUMENT

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PAH

CAS No.

IRIS

(a)

Cal
EPA

(b)

WHO

EHC
(1998)
(c)

ATSDR

Tox.
Profile

(1995) (d)

TCL
(Priority
Pollutant)
List (e)

Superfund
Site TIC

(f)

Cyclopenta[
-------
PAH

CAS No.

IRIS

(a)

Cal
EPA
(b)

WHO

EHC
(1998)
(c)

ATSDR

Tox.
Profile
(1995) (d)

TCL
(Priority
Pollutant)
List (e)

Superfund
Site TIC

(f)

Triphenylene

217-59-4

(a) Included in EPA's Integrated Risk Information System (IRIS) database.

(b) Included among the PAHs for which California EPA has derived potency equivalency factors (Cal EPA,
1999).

(c) Included in the International Programme on Chemical Safety (IPCS)/WHO 1998 Environmental Health
Criteria document for selected non-heterocyclic PAHs on the basis of the availability of relevant data on
toxicological end-points and/or exposure.

(d) Included in the Agency for Toxic Substances and Disease Registry toxicological profile for PAHs (ATSDR,
1995) on the basis of the availability of reliable health-based and environmental information.

(e) Included on the Target Compound List (TCL) - the list of organic compounds for which monitoring is
routinely performed at Superfund and other waste sites. All but one of the TCL compounds are also priority
pollutants.

(f) Reported as a tentatively identified compound (TIC) at least 10 times in soil samples collected between
2/1/1995 and 12/31/2000 at predominately Superfund sites.

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DISCUSSION DOCUMENT

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APPENDIX B

Surrogate Approach Developed by Foureman and Smith (1999)

Dr. Gary Foureman of EPA's National Center for Environmental Assessment and Dr.
Roy Smith of EPA's Office of Air Quality Planning and Standards developed an approach for
assessing the health risk of PAH mixtures in air using data for a sufficiently similar PAH mixture
that is similar to the standard surrogate approach but also includes a procedure for evaluating
whether or not differences in composition are likely to be toxicologically significant. The
approach assumes that all PAH-containing mixtures in air are essentially the same as a mixture
of coal tar pitch (CTP) - a PAH mixture of known composition and carcinogenic potency, and
that the concentrations of B[a]P and other detected airborne PAHs are simply dilutions of CTP.
This application of a surrogate approach using data for sufficiently similar mixtures is presented
in Foureman and Smith (1999).

In applying this approach, an inhalation unit risk (UR) of 1 x 10"4 (pig CTP/m3)"1 was
obtained for CTP based on lung tumor formation in female Wismar rats exposed to a CTP
aerosol (Heinrich et al., 1994). The actual concentration of individual PAHs in CTP was
obtained from the Heinrich et al. (1994) study (see Table B-l).

TABLE B-l

Information Applied in the Surrogate Approach of Foureman and Smith (1999)

PAHs in CTP Used in the
Heinrich et al. Bioassay
(ng PAH/m3 in 1 /ig CTP/m3)

PAH Cone, in ARM 1597

PAH of Concern

Absolute Cone.

(ng/^g)

Cone. Relative to
B[a]P

RPF

Bcnzo|fl|pyrcnc

17.7

95.8

Benz [a] anthracene

22.3

98.6

0.1

Benzo [/>]fluoranthene

8.8

0.7

0.1

Benzo [&]fluoranthene

0.4

0.1

Indeno [ 1.2.3-«/|pyrcnc

11.2

60.2

0.6

0.1

Chrysene

22.7

71.7

0.8

0.01

Dibenz | ah] anthracene

Assuming B[a]P (or some other PAH) is present in the PAH mixture of interest in the
same proportion as it is in CTP (i.e., that the airborne PAHs in the mixture of interest occur as
dilutions of CTP), the carcinogenic risk of the environmental mixture can be calculated by ratio.
For example, given a B\a\P concentration in an environmental mixture of 3 ng B[a]P/m3, the
incremental cancer risk associated with the mixture would be estimated as follows:

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DISCUSSION DOCUMENT

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17.7 ngBaP/m3 3 ngBaP/m3
1 jlgCTP I m3 x

x = 0.17 jlgCTP Im3

Risk = 0.17jlgCTP /m3 x [IxlO 4 (jlgCTP Im3yl]

The above procedure holds only if the environmental mixture of interest is "sufficiently
similar" to CTP, the reference mixture. This determination is made by comparison of the
mixture of interest to the composition of PAHs in a standard coal tar material. The National
Institute of Standards and Technology has developed and analyzed a Standard Reference
Material (SRM) 1597, Complex Mixture of Polycyclic Aromatic Hydrocarbons from Coal Tar.
This mixture is described as a natural combustion-related mixture of PAHs isolated from a coal
tar. [The distribution of PAHs in the CTP used in the Heinrich et al. (1994) bioassay closely
resembles the distribution in SRM 1597.] The composition of SRM 1597 for six PAHs of
concern is shown in Table B-l. Concentrations are presented both as the absolute concentration
in SRM 1597 and as the concentration relative to B[a]P. The concentration of individual PAHs
in the mixture of interest, also expressed relative to B[a]P, can be compared to the relative PAH
concentrations in SRM 1597 to reach a judgment about the similarity of the mixtures.

To determine whether differences in composition are likely to be of toxicological
significance, qualitative evaluations based on the relative potency factors (RPFs) from Nisbet
and LaGoy (1992) are performed.8 For example, compositional differences in chrysene, with a
small RPF, would not be expected to significantly alter the potency of the mixture relative to the
reference mixture. In contrast, compositional differences in benz[a]anthracene, with a RPF of 1,
might alter the mixture potency.

8 Note that Nisbet and LaGoy (1992) used the term TEF (toxicity equivalence factor), but
because of their limited scope of application these factors are more properly termed RPFs
according to current EPA guidance.

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References

Heinrich, U., M. Roller, and F. Pott. 1994. Estimation of a lifetime unit lung cancer risk for
benzo(a)pyrene based on tumour rates in rats exposed to coal tar/pitch condensation aerosol.
Toxicol Letters 72: 155-161.

Nisbet, I.C.T., and P.K. LaGoy. 1992. Toxic equivalency factors (TEFs) for polycyclic aromatic
hydrocarbons (PAHs). Reg. Toxicol. Pharmacol. 16:290-300.

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