Shortcomings in USEPA's Approach for Predicting Risk Due to Consumption of Animal Food Products Impacted by Air Emissions from Hazardous Waste Combustion Facilities: A Case Study Involving Phthalates

As a part of the permitting process for hazardous waste combustion facilities, regulatory agencies are now conducting site-specific, multipathway risk assessments. In accordance with the approach established by the USEPA, the Texas Natural Resource Conservation Commission uses a prospective risk assessment paradigm whereby site-specific activity pattern and land use information is used to determine plausible exposure scenarios and pathways. A set of exposure scenarios defined as receptors (i.e., resident adult, resident child, farmer adult, farmer child, fisher adult and fisher child) is then assumed to be exposed via multiple applicable exposure pathways. In conducting such risk assessments, modeled air emissions of di-n-octyl phthalate (DNOP), at concentrations near or below detectable levels, have been observed to produce an unacceptable hazard in the farmer exposure scenario. Sensitivity analyses indicated that two key parameters affected hazard estimates for DNOP in the farmer scenario: the octanol-water partition coefficient (K_ow), which is used to predict bioaccumulation in animal tissue, and the metabolism factor, which is used to account for metabolism and elimination. Evidence indicates that K_ow values for highly lipophillie compounds are accurately determined using a slow-stir method. In addition, evidence indicates that the phthalates of interest are extensively metabolized and eliminated. However, current USEPA guidance includes geometric mean K_ow values for highly lipophillie compounds derived in part on methods that are outdated and no longer considered accurate. In addition, USEPA guidance only considers metabolism for bis-% ethylhexyl phthalate (BEHP). Collectively, these two shortcomings in the USEPA approach result in a 38-fold underestimation of hazard for BEHP and a 172,000-fold overestimation of hazard for DNOP.