The FQPA 10X Safety Factor: How Much is Science? How Much is Sociology?

On August 3, 1996, the Food Quality Protection Act of 1996 (FQPA) was signed into law. The FQPA instructed the U.S. Environmental Protection Agency, in making its “reasonable certainty of no harm” finding, that in “the case of threshold effects,…an additional tenfold margin of safety…shall be applied for infants and children to take into account potential pre- and postnatal toxicity and completeness of data with respect to exposure and toxicity to infants and children.” The law further states that “the Administrator may use a different margin of safety……only if, on the basis of reliable data, such margin will be safe for infants and children.” This paper describes how the Office of Pesticide Programs of the U.S. Environmental Protection Agency proposes to implement this legislative mandate in its 1999 draft.     

U.S. EPA Reference Dose/Reference Concentration Methodology: Update on a Review of the Process

The U.S. Environmental Protection Agency (USEPA) has been reviewing several approaches to testing and risk assessment related to implementation of the Food Quality Protection Act (FQPA) and the Amendments to the Safe Drinking Water Act (SDWA), both signed into law in 1996. Based on recommendations from a review of issues related to children's health protection under these laws, the USEPA established the RfD Technical Panel to evaluate in depth the current reference dose (RfD) and reference concentration (RfC) process in general, and in particular with respect to how well children and other potentially sensitive subpopulations are protected. The RfD Technical Panel also was asked to consider scientific issues that have become of greater concern in RfD and RfC derivation (e.g., neurotoxicity, immunotoxicity), and to raise issues that should be explored or developed further for application in the RfD/RfC process. This paper provides the current status of the activities of the RfD Technical Panel. The Technical Panel has recommended that acute, short- term, and intermediate reference values should be set for chemicals, where possible, and that these values should be incorporated into the USEPA's Integrated Risk Information System (IRIS) Database. A review of current testing procedures is underway, including the endpoints assessed, life stages covered by exposure and outcome evaluation, and information that can be derived from current protocols on various durations of exposure. Data gaps identified for risk assessment include the types of pharmacokinetic data that should be collected, especially for developmental toxicity studies, the impact of aging on toxic responses occurring after early exposure as well as concomitant with exposure in old age, and information available on latency to response. The implications of the RfD Technical Panel's recommendations for various uncertainty factors are also being explored.     

The Value of Human Testing of Pesticides

Recently, the issue of using human volunteers as subjects for studying the potential toxicity of pesticides has received public attention through the media and subsequently in the regulatory arena. The debate has focused on whether such studies are ethical per se and if data from these investigations should be used for regulatory decisions. The precipitating event that prompted the current debate was the enactment of the Food Quality Protection Act (FQPA) of 1996. The FQPA, which amended the two laws governing the regulation of pesticides in the United States, requires the Environmental Protection Agency to reassess all of the nearly 10,000 tolerances (maximum allowable residues in food) and exemptions from tolerances that were in place when the law went into effect. When reassessing tolerances the U.S. Environmental Protection Agency (USEPA) reviews the data, including toxicology, available on each pesticide to determine if they are adequate to allow the Agency to make the necessary safety finding. Historically, it had been considered acceptable to conduct and use data from studies of exposure to chemicals (including pesticides) of human volunteers if these studies were conducted according to specific criteria as outlined in the Helsinki Declaration and Common Rule. Now this philosophy is being challenged and the USEPA is faced with answering the question of whether pesticides should be viewed as different, from an ethical standpoint, from other chemicals, and how such data should be used in the risk assessment process. The following paper makes an argument for the use of human volunteer testing of pesticides applying the logic that, if one wants to protect humans from the potential harm that may occur from eating foods containing pesticides, one must use the best possible data available. There can be little doubt that the best data for predicting the toxicity of a chemical in humans is to obtain and use human data, as long as it is obtained in an ethical manner.     

Comparison of Two U.S. Environmental Protection Agency Species Sensitivity Distribution Methods for Calculating Ecological Risk Criteria

Two major methods used by the U. S. Environmental Protection Agency (USEPA) to calculate ecological risk criteria using “species sensitivity distributions” (SSD) are compared using identical datasets. One method is the current USEPA Office of Water method for deriving acute numeric water quality criteria (EPA-FAV method). The 95% protection level generated by this method is the Final Acute Value (FAV). The other method is the USEPA Office of Pesticide Programs log normal distribution regression method that uses all available toxicological data in performing ecological risk assessments (OPP-Ecorisk method). Of the 50 comparisons made, 38% of the 95% protection levels calculated by the OPP-Ecorisk method are within a factor of 1.5 of the EPA FAV, 68% are within a factor of 2.0, 86% are within a factor of 2.5 and 92% are within a factor of 3.5. For pollutants where the difference between the OPP-Ecorisk 95% protection level and the EPA FAV are greatest, the OPP-Ecorisk 95% protection level is more protective than the EPA FAV. Where there are major differences, an analysis of the toxicity data indicates that the majority of the differences can be attributed to outliers, especially on the least sensitive ends of the toxicity distribution. In the one example dataset presented with one very sensitive genus, the OPP-Ecorisk method gave a protection level that was much closer to the lowest GMAV than the EPA-FAV method.     

Methyl Ethyl Ketone Safety Characterization for Infants and Children: Assessment in the USEPA Voluntary Children's Chemical Evaluation Program

A safety characterization specific to children was performed for methyl ethyl ketone (MEK) according to the guidelines of the Voluntary Children's Chemical Evaluation Program (VCCEP). The characterization indicates that MEK exposures are not expected to pose an acute or chronic risk to children. Hazard information, summarized as per the VCCEP Tier structure, indicated no need for additional studies. All exposure pathways potentially relevant to children were considered, including child contact with environmental media, food, drinking water, parental transfer to child (human milk or dermal contact), direct consumer product use, and presence during product use. The assessment found that exposures from anthropogenic sources that children may encounter on a daily basis are very low, and in particular well below the chronic inhalation and oral health benchmarks (RfC and RfD) derived by the U.S. Environmental Protection Agency (USEPA). Indoor uses of consumer products can result in higher acute exposures, but these are short-lived and also fall below chronic benchmarks adjusted to an acute timeframe. In addition, MEK is rapidly metabolized and excreted, thus acute exposures do not lead to an increase in body burden over time. The USEPA concluded the VCCEP submission sufficiently characterized potential risks to children, and that no additional toxicity tests were needed for MEK.     

Sustainability of insect resistance management strategies for transgenic Bt corn

Increasing interest in the responsible management of technology in the industrial and agricultural sectors of the economy has been met thorough the development of broadly applicable tools to assess the "sustainability" of new technologies. An arena ripe for application of such analysis is the deployment of transgenic crops. The new transgenic pesticidal or plant-incorporated protectant (PIP) crops have seen widespread application in the United States based on the features of higher yield, lower applications of insecticides, and control of mycotoxin content. However, open rejection of these new crops in Europe and in other countries has been a surprising message and has limited their worldwide acceptance. The US Environmental Protection Agency's (USEPA) Office of Pesticide Programs (OPP) has worked on the development and analysis of insect resistance management (IRM) strategies and has mandated specific IRM requirements for Bacillus thuringiensis (Bt) crops since 1995 under the Food, Fungicide, Insecticide, and Rodenticide Act. Improvement of data quality and sustainability of IRM strategies have been targeted in an ongoing partnership between the USEPA Office of Research and Development and the Office of Pesticide Programs that will further enhance the agency's ability to develop sustainable insect resistance management strategies for transgenic field corn (Bt corn) producing B. thuringiensis (Bt) insecticidal proteins.     

Inter- and Intra-Species Extrapolation in Risk Assessment of Different Classes of Pesticides

Risk assessors routinely use the reference dose (RfD) approach for non-cancer risk assessment. In this approach, No-Observed-Adverse-Effect-Level (NOAEL) is divided by the product of uncertainty factors (UFs) and, occasionally, an additional modifying factor (MF), each usually employed by default as factors of 10. In the present investigation, kinetic and dynamic data have been used in order to reduce uncertainties when establishing exposure guidelines for examples of chemicals representing four classes of pesticides (warfarin, lindane, carbaryl and parathion). An intensive search of databases was conducted for these pesticides, and toxicokinetic and toxicodynamic parameters in inter- and intra-species were evaluated. The kinetic and dynamic subfactors were less than the proposed values of Renwick and the International Programme on Chemical Safety (IPCS). The composite factors for all the examined pesticides were less than 100. The present study indicated that in setting exposure levels it is important to incorporate kinetic and dynamic data, as they become available, rather than rely on default uncertainty factors, which are imprecise in many cases.     

A survey of EPA/OPP and open literature on selected pesticide chemicals. III. Mutagenicity and carcinogenicity of benomyl and carbendazim

The known aneuploidogens, benomyl and its metabolite, carbendazim (methyl 2-benzimidazole carbamate (MBC)), were selected for the third in a series of ongoing projects with selected pesticides. Mutagenicity and carcinogenicity data submitted to the US Environmental Protection Agency's (US EPA's) Office of Pesticide Programs (OPP) as part of the registration process are examined along with data from the open literature. Mutagenicity and carcinogenicity profiles are developed to provide a complete overview and to determine whether an association can be made between benomyl- and MBC-induced mouse liver tumors and aneuploidy. Since aneuploidogens are considered to indirectly affect DNA, the framework adopted by the Agency for evaluating any mode of action (MOA) for carcinogenesis is applied to the benomyl/MBC data.Both agents displayed consistent, positive results for aneuploidy induction but mostly negative results for gene mutations. Non-linear dose responses were seen both in vitro and in vivo for aneuploidy endpoints. No evidence was found suggesting that an alternative MOA other than aneuploidy may be operative. The data show that by 14 days of benomyl treatment, events associated with liver toxicity appear to set in motion the sequence of actions that leads to neoplasms. Genetic changes (as indicated by spindle impairment leading to missegregation of chromosomes, micronucleus induction and subsequent aneuploidy in bone marrow cells) can commence within 1-24h after dosing, well within the time frame for early key events. Critical steps associated with frank tumor formation in the mouse liver include hepatotoxicity, increased liver weights, cell proliferation, hypertrophy, and other steps involving hepatocellular alteration and eventual progression to neoplasms. The analysis, however, reveals weaknesses in the data base for both agents (i.e. no studies on mouse tubulin binding, no in vivo assays of aneuploidy on the target tissue (liver), and no clear data on cell proliferation relative to dose response and time dependency). The deficiencies in defining the MOA for benomyl/MBC introduce uncertainties into the analysis; consequently, benomyl/MBC induction of aneuploidy cannot be definitively linked to mouse liver carcinogenicity at this time.     

The Health Risk Assessment Performed in California for the Herbicide Simazine: A Case Study

Simazine, a member of the triazine group, is registered in California for weed control in soils where a wide range of crops will be (or are) planted. The health risks from simazine use in California were recently assessed by the California Department of Pesticide Regulation (CDPR) for all potential (acute and long-term) exposure scenarios relevant to Californian residents and workers. The results of the CDPR risk assessment indicate that current exposure levels in many of the scenarios under consideration are not health protective for the people in California. The main objective of the present summary report (i.e., case study) was two-fold, both for offering a forum to advance further scientific discussion: (1) to highlight the toxicity and exposure data as well as the assumptions used in the CDPR simazine risk assessment and then (2) to systematically requalify the uncertainties and complexities involved in terms of the toxicity and exposure appraisals given in that risk assessment. In both attempts, the focus was more on residential exposures for young children and women of child-bearing age in that simazine was reportedly seen to exhibit neuroendocrine effects across a variety of species.     

A survey of EPA/OPP and open literature on selected pesticide chemicals. II. Mutagenicity and carcinogenicity of selected chloroacetanilides and related compounds.

With this effort, we continue our examination of data on selected pesticide chemicals and their related analogues that have been presented to the U.S. Environmental Protection Agency's (USEPA's) Office of Pesticide Programs (OPP). This report focuses on a group of selected chloroacetanilides and a few related compounds. As part of the registration process for pesticidal chemicals, interested parties (registrants) must submit toxicity information to support the registration including both mutagenicity and carcinogenicity data. Although this information is available to the public via Freedom of Information (FOI) requests to the OPP, publication in the scientific literature allows greater dissemination and examination of the data. For this Special Issue, graphic profiles have been prepared of the mutagenicity and carcinogenicity data available in the submissions to OPP. Also, a discussion is presented about how toxicity data are used to help establish tolerances (limits of pesticide residues in foods). The mutagenicity results submitted by registrants are supplemented by data on these chemicals from the open literature to provide a full perspective of their genetic toxicology. The group of chloroacetanilides reviewed here display a consistent pattern of mutagenic activity, probably mediated via metabolites. This mutagenic activity is a mechanistically plausible factor in the development of tumors seen in experimental animals exposed to this class of chemicals.     

Framework for the Integration of Health and Ecological Risk Assessment

The World Health Organization's International Programme on Chemical Safety (IPCS), the Organization for Economic Cooperation and Development (OECD), and the U.S. Environmental Protection Agency have developed a collaborative partnership to foster integration of assessment approaches for human health and ecological risks. This paper presents the framework developed by that group. Integration provides coherent expressions of assessment results, incorporates the interdependence of humans and the environment, uses sentinel organisms, and improves the efficiency and quality of assessments relative to independent human health and ecological risk assessments. The paper describes how integration can occur within each component of risk assessment, and communicates the benefits of integration at each point. The goal of this effort is to promote the use of this internationally accepted guidance as a basis for harmonization of risk assessment.     

Studies on the use of uncertainty factors in deriving RfDs

Risk assessment of exposure to chemicals having a toxic end point routinely uses the reference dose (RfD) approach based on uncertainty factors of 10. RfD model can be used with widely different databases. However, the quality of individual risk assessment is unequal among chemicals, often resulting in either an over‐ or underestimation of adverse health risk. The purpose of this investigation was to evaluate whether the magnitude of the 10X uncertainty factors has scientific merit against data from recent human and animal experimental studies. Although we assessed the use of uncertainty factors for representative chemicals from various classes of compounds, such as volatile organics, alcohols, gasoline components, and pesticides, we are presenting our findings for 24 chemicals.

A compilation and comparison of ratios between LOAEL/NOAEL (Lowest Observed Adverse Effect Level/No Observed Adverse Effect Level), and subchronic/chronic values were made. Although a 10X uncertainty factor is most commonly used in the risk assessment processes, an examination of the datasets which have been used to calculate RfDs suggests different values which are scientifically justifiable.     

Noncancer Risk Assessment: A Probabilistic Alternative to Current Practice

Based on imperfect data and theory, agencies such as the United States Environmental Protection Agency (USEPA) currently derive “reference doses” (RfDs) to guide risk managers charged with ensuring that human exposures to chemicals are below population thresholds. The RfD for a chemical is typically reported as a single number, even though it is widely acknowledged that there are significant uncertainties inherent in the derivation of this number.

In this article, the authors propose a probabilistic alternative to the EPA's method that expresses the human population threshold as a probability distribution of values (rather than a single RfD value), taking into account the major sources of scientific uncertainty in such estimates. The approach is illustrated using much of the same data that USEPA uses to justify their current RfD procedure.

Like the EPA's approach, our approach recognizes the four key extrapolations that are necessary to define the human population threshold based on animal data: animal to human, human heterogeneity, LOAEL to NOAEL, and subchronic to chronic. Rather than using available data to define point estimates of “uncertainty factors” for these extrapolations, the proposed approach uses available data to define a probability distribution of adjustment factors. These initial characterizations of uncertainty can then be refined when more robust or specific data become available for a particular chemical or class of chemicals.

Quantitative characterization of uncertainty in noncancer risk assessment will be useful to risk managers who face complex trade-offs between control costs and protection of public health. The new approach can help decision-makers understand how much extra control cost must be expended to achieve a specified increase in confidence that the human population threshold is not being exceeded.     

Current Perspectives on Issues in Risk Assessment Methods

The Office of Research and Development (ORD) of the U.S. Environmental Protection Agency was reorganized in 1995 to follow the risk assessment paradigm developed by the National Research Council. With the reorganization, a number of different research strategies and plans were developed on problem-driven topics (e.g., arsenic, particulate matter, and microbial pathogens/disinfectant byproducts) as well as on core research (e.g., ecological research, human health risk assessment research, and pollution prevention research). The human health risk assessments research strategy, which is currently under development, addresses a variety of issues which affect all human health risk assessments. These include mechanism of action, variation in response, aggregate risk, and effect on public health. While all of the issues that have been identified are important, the challenge to ORD is to identify which will have the greatest impact on improving risk assessment so that resources can be most strategically applied.     

Uncertainty Analysis of Pesticide Residues in Drinking Water Risk Assessment

Pesticide residues in drinking water can vary significantly from day to day. However, water quality monitoring performed under the Safe Drinking Water Act (SDWA) at most community water systems (CWSs) is typically limited to four data points per year over a few years. Due to this limited sampling, likely maximum residues may be underestimated in risk assessment. In this work, a statistical methodology is proposed to study two types of uncertainties in observed samples and their propagated effect in risk estimates. The methodology was demonstrated using data from 16 CWSs that have three independent databases of atrazine residue to estimate the uncertainty of risk in infants and children. The results showed that in 85% of the CWSs, chronic risks predicted with the proposed approach may be two- to four-folds higher than that predicted with the current approach, wheras intermediate risks may be two- to three-folds higher in 50% of the CWSs. In 12% of the CWSs, however, the proposed methodology showed a lower intermediate risk. A closed-form solution of propagated uncertainty was developed to demonstrate the number of years (seasons) of data and sampling frequency needed to reduce the uncertainty of risk estimates. In general, this methodology provided good insight into the importance of addressing uncertainty of observed water quality data and the need to predict likely maximum residues in risk assessment.     

Approaches for Integrated Risk Assessment

Recognizing the need to enhance the effectiveness and efficiency of risk assessments globally, the World Health Organization's International Programme on Chemical Safety, the U.S. Environmental Protection Agency, the European Commission, and the Organization for Economic Cooperation and Development developed a collaborative partnership to foster integration of assessment approaches used to evaluate human health and ecological risks. The objectives of this effort included: improving understanding of the benefits of integration, identifying obstacles to the integration process, and engaging key agencies, organizations, and scientific societies to promote integration. A framework with supporting documentation was developed to describe an approach for integration. Four case studies were constructed to illustrate how integrated risk assessments might be conducted for chemical and nonchemical stressors. The concepts and approaches developed in the project were evaluated in an international workshop. The goal of this effort was international acceptance of guidance for integrated risk assessment.     

Metal residues in flesh of edible blue crab,Callinectes amnicola,from a tropical coastal lagoon: Health implications

Metals such as cadmium (Cd), lead (Pb), zinc (Zn), and copper (Cu) were estimated in the flesh of the edible blue crab Callinectes amnicola from selected areas of the Lagos Lagoon, Nigeria (i.e., Makoko, Iddo, Okababa, Ikoyi, and Ajah) for 18 months between March 2011 and August 2012. Estimated average daily intake (EADI) and target hazard quotient (THQ) were used to determine the risk implications for adult and child consumer populations. Range of Cd, Pb, Zn, and Cu across sites was 0.16–0.46, 1.48–3.17, 2.21–3.65, and 9.48–12.76 mg kg^?1 crab flesh wet weight, respectively. Lead concentrations in crab flesh from Makoko (3.16 ± 1.44 mg kg^?1) and Iddo (5.17 ± 1.26 mg kg^?1) exceeded the maximum accepted limits recommended by the Food and Agriculture Organization/World Health Organization for food fisheries. The EADI across sites for the adult consumer population exceeded the reference dose (RfD) recommended by the U.S. Environmental Protection Agency for most metals with magnitude of ≤7-fold while EADI of Pb among child consumer population across sites exceeded RfD by a maximum of 4.5-fold. THQs for adult population were >1 for all metals across all sites, and >1 for Pb and Cd for selected sites for the child consumer population. Findings from this study indicate higher health risks of metal toxicity to adult consumer populations, and risks of lead toxicity to child consumer populations around the Lagos Lagoon, Nigeria.     

A Risk Assessment Framework for Waterborne Pathogens and Requirements for Producing a Complete Protocol

The U.S. Environmental Protection Agency (USEPA), Office of Water, is developing a risk assessment protocol for determining microbiological pathogen risks in water (drinking, recreational, waste waters, etc.). This effort has been conducted in collaboration with the International Life Sciences Institute. A microbiological risk assessment framework was prepared and has been peer reviewed in the open literature and vetted at the USEPA and other federal government risk assessment venues. Some goals in development of the Framework were to make it comprehensive, easy to understand and to use, since it is recognized that improvements to the framework structure and instructional material would facilitate its use. The USEPA's Office of Water wishes to develop improved tools, methods, and approaches for conducting the analysis phase for risk assessments and would like to evaluate its efficacy for a broad range of waterborne pathogens in water/wastewater media. Improved understanding of microbiological survival, infectivity, and virulence factors is needed, especially at the genomic and proteomic levels to accurately assess the occurrence and fate of pathogens in water and to predict what intrinsic factors allow pathogens to be invasive and virulent. Development of improved dose-response models (including animal models) for pathogen exposures focusing on the dynamic circumstances of immunity, secondary spread, and sensitive subpopulations, would be useful additions to the Framework. In the future, USEPA may consider establishing comprehensive pathogen risk assessment guidelines that all its program offices can use.     

Relevance of the 10X Uncertainty Factor to the Risk Assessment of Drugs Used by Children and Geriatrics

Conventional risk assessment practices utilize a tenfold uncertainty factor (UF) to extrapolate from the general human population to sensitive subgroups, such as children and geriatrics. This study evaluated whether the tenfold UF can be reduced when pharmacokinetic and pharmacodynamic data for pharmaceuticals used by children and geriatrics are incorporated into the risk assessment for human sensitivity. Composite factors (kinetics X dynamics) were calculated from data-derived values for bumetanide, furosemide, metoprolol, atenolol, naproxen, and ibuprofen. For the compounds examined, all of the composite factors were lower than 10. Furthermore, 8 of the 12 composite factors were less than 5.5. Incorporation of human kinetic and dynamic data into risk assessment can aid in reducing the uncertainties associated with sensitive subgroups and further study is encouraged.     

Framework for Human Health Risk Assessment

The U.S. Environmental Protection Agency has recognized the need to develop a framework for human health risk assessment that puts a perspective on the approaches in practice throughout the Agency. In response, the Agency's Risk Assessment Forum has begun the long-term process of developing a framework for human health risk assessment. The framework will be a communication piece that will lay out the scientific basis, principles, and policy choices underlying past and current risk assessment approaches and will provide recommendations for integrating/harmonizing risk assessment methodologies for all human health endpoints.