1. Brazilian Benzene Seminar
Brasilia, Brazil
December 5, 2012
Rita Schoeny, Ph.D.
Senior Science Advisor,
Office of Science Policy, Office of Research and Development
U.S. EPA
1
2. Disclaimer
The views expressed in this presentation
are those do the author and do not
represent the policy of the U.S. EPA.
Some of this is EPA policy
2
3. So What Is EPA Policy?
Science Policy
Defaults, methods, Guidelines
Used when there are data or methodology gaps
Peer reviewed
Lots of documentation, which is publicly available
Policy based on science
May be set by EPA Executive Level
Generally involves regulations or other risk
management choices; science is peer reviewed, action
involves public comment; May be subject to Federal
Advisory Committee Act
Lots of documentation; may be docket; publicly
available
3
4. Examples
Science policy
Cancer Guidelines 2005
Set a reference dose for effects which are likely to
have a threshold
Quantitative adjustment to cancer risk for early life
exposure
Animal data are relevant to humans unless
demonstrated otherwise
4
5. Examples
Policy set on science
Drinking Water Regulations are set as close as
feasible to a Maximum Contaminant Level Goal
Consideration of residual risk after setting and
air regulation requiring Maximum Achievable
Control Technology
○ What we are currently doing for electrical power
plants
Cost / benefit choices
5
6. SDWA ‗96
Does the contaminant adversely affect Regulate with
public health?
NPDWR
Is the contaminant known or likely to occur in
PWSs with a frequency and at levels posing a
threat to public health?
These are questions,
Will regulation of the contaminant present a demonstrations of risk
meaningful opportunity for health risk reduction?
6
8. A lot has changed since ‗83
Exposure
Science in the
21st Century:
A Vision and A
Strategy
IPCS FRAMEWORK FOR ANALYSING THE
RELEVANCE OF A CANCER MODE OF ACTION
FOR HUMANS
8
9. NRC Silver Book
Recommendation
NRC Silver Book recommendation (Chapter
8 ―Improving Utility of Risk Assessment‖)
To make risk assessments most useful for risk
management decisions, the committee
recommends that EPA adopt a framework for risk-
based decision-making . . . that embeds the Red
Book risk assessment paradigm into a process
with initial problem formulation and scoping,
upfront identification of risk-management options
and use of risk assessment to discriminate among
these options.
9
10. Draft HHRA Framework
Silver Book on Utility
“Risk assessments
Planning & Scoping
and Problem Formulation should not be
Conceptual Analysis
conducted unless it is
clear that they are
Confirmation of Utility
Model Plan
Risk Assessment
designed to answer
Public/
Community/ specific questions, and
Effects Assessment
Stakeholder Exposure
Hazard Identification that the level of
Assessment
Involvement Dose Response
technical detail and
Risk Characterization
uncertainty and
variability analysis is
appropriate to the
Informing Decisions decision context” (NRC
2009, p. 247).
10
14. A Generalized Conceptual Model
(adapted from USEPA, 2002; 2003)
Sources Stressors Exposure Pathways/Routes Receptors Endpoints Risk Metrics
Activities that
generate/release
Stressors or Chemical,
types of stressor physical or
releases biological
agents Physical processes
that cause or interactions by which
an effect a stressor is brought
into to contact with Populations
receptor and/or
lifestages
exposed to Measures of
the stressor stressor
effects or
biological
systems Metrics by
affected which risk is
quantified
(e.g., disease
cases, hazard
quotients,
magnitude of
effect)
15. Sources Stressors Exposure Receptors Endpoints Risk
Pathways/ Metrics
Drinking water
disinfection Routes
Variable
mixture
nitrosamines;
dependent on Conceptual Model
treatment & Nitrosamines in Drinking Water
source water. Ingestion of
nitrosamine
mixture in
drinking water Consumers of
drinking
water;
includes
sensitive
populations
& life stages
Cancer,
any site or
type
Combined
risk of cancer
from subset
nitrosamines
in mixture
16. Cancer Guidelines: What‘s Different
from 1986?
Analyze data before invoking default options.
Mode of action is key in decisions
Weight-of-evidence narrative replaces the
previous ―A-B-C-D-E‖ classification scheme.
Two step dose response assessment
Model in observed range
Extrapolate from point of departure
Consider linear and non-linear extrapolation
Address differential risks to children
12/10/2012 16
17. Risk Assessment Science
Use Data Before Invoking Defaults
Analyze the available data
Is there too much uncertainty or Invoke a
is critical information lacking? default option
Y
N
Conduct risk assessment
17
18. Cancer Guidelines: What‘s Different
from 1986?
Analyze data before invoking default options.
Mode of action is key in decisions
Weight-of-evidence narrative replaces the
previous ―A-B-C-D-E‖ classification scheme.
Two step dose response assessment
Model in observed range
Extrapolate from point of departure
Consider linear and non-linear extrapolation
Address differential risks to children
12/10/2012 18
19. Human Animal Indirect,
Other
IARC US EPA NTP
Sufficient -- --
Carcinogenic to
Strong human Carcinogenic to Known to Be Human
humans
mechanistic humans Carcinogen
(Group 1)
Limited Sufficient data
-- Probably
carcinogenic to
Sufficient Strong humans
(Group 2A)
Inadequate Limited Strong
Likely to be
Sufficient -- carcinogenic to Reasonably
humans Anticipated to Be
Limited Limited -- Possibly Human Carcinogen
carcinogenic to
Strong & same humans
class as other (Group 2B)
Inadequate Inadequate carcinogens
Strong/ Inadequate
convincing Information to Assess
Inadequate Limited -- Not classifiable Suggestive Not classified
19
Zeise EEA Copenhagen Sept 3, 2010
20. Cancer Guidelines: What‘s Different
from 1986?
Analyze data before invoking default options.
Mode of action is key in decisions
Weight-of-evidence narrative replaces the
previous ―A-B-C-D-E‖ classification scheme.
Two step dose response assessment
Model in observed range
Extrapolate from point of departure
Consider linear and non-linear extrapolation
Address differential risks to children
12/10/2012 20
21. Mode of Action and Cancer
Assessment
MOA is the keystone to all aspects of
the assessment process
True for other endpoints
and is the major factor in
harmonization among risk
assessments
21
22. Why Do You Care about
MOA ?
MOA is key in Hazard Identification
Helps describe circumstances under which
agent is carcinogenic (High dose? Route?)
Relevance of data for humans
MOA determines choice of Low Dose
Extrapolation
Life stage risk
R esponse (T u m o r o r N on tu m o r D ata)
e)
os
D
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O b s e rv a tio n
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L in
x x
0%
L E D 10 E D 10
MOE x N O AEL
N o n lin e a r D e fa u lt
D ose x LO AEL
22
23. Breaking Down the Dichotomy
Cancer Non-Cancer
Threshold
Non-Threshold
Reversible
Irreversible
Safety Value
Risk value
RfD/RfC
Slope Factor
ADI/TDI
Unit Risk
MRL
Risk-Specific Dose
23
24. Mode of Action Exposure
―. . . a sequence of key Key event
events and processes,
starting with interaction of an
agent with a cell, proceeding
through operational and
anatomical changes, and
resulting in cancer Key event
formation. . . Mode of action is
contrasted with ―mechanism of
action,‖ which implies a more
detailed understanding and
description of events, often at the
molecular level, than is meant by
mode of action‖
Key event
Toxicity 24
25. Mode of Action Frameworks
U.S. EPA IPCS
Postulated mode of action
Hypothesized MOA: summary (theory of the case)
description and identification Key events
of key events Concordance of dose-
Experimental support: response relationships
Strength, consistency, Temporal association
specificity of association Strength, consistency and
Dose-response specificity of association of
concordance tumour response with key
Temporal relationship
events
Biological plausibility and
Biological plausibility and coherence
coherence Other modes of action
Consideration of the Uncertainties,
possibility of other MOAs Inconsistencies, and Data
Relevance to humans Gaps
Assessment of postulated
mode of action
25
26. MOA/Human Relevancy ILSI/IPCS
NO
Is the weight of evidence Proceed with
sufficient to establish a mode risk assessment
of action (MOA) in animals?
YES
Can human relevancy of the MOA be
YES reasonably excluded on the basis of
MOA not fundamental, qualitative differences in
Relevant key events between
animals and humans?
NO
Can human relevancy of the MOA be
reasonably excluded on the basis of NO
YES
MOA not quantitative differences in either Proceed with
Relevant kinetic or dynamic factors between Risk assessment
animals and humans?
26
27. Key Event
A “key event” is an empirically observable
precursor step that is itself a necessary
element of the mode of action or is a
biologically based marker for such an
element.
Key event is necessary, but not sufficient
If a key event doesn‘t occur, there is no
cancer
If one key event occurs, there may or may
not be cancer
27
28. Postulated Mode Of Action
Chloroform
Sustained Toxicity
Regenerative Cell Proliferation
Key Events
Tumor Development
28
29. Postulated Mode Of Action
Metabolism CP
DNA damage
Tumor
Development Mutations
29
30. Mode of Action Framework
Hypothesized MOA: summary description
and identification of key events
Experimental support:
Strength, consistency, specificity of association
Dose-response concordance
Temporal relationship
Biological plausibility and coherence
Consideration of the possibility of other
MOAs
Relevance to humans
12/10/2012 30
31. Based on ―Hill Criteria‖ for
Causality
―None of my nine viewpoints
Experimental support: can bring indisputable
Strength, consistency, evidence for or against the
cause-and-effect hypothesis
specificity of and none can be required
association as a sine qua non. What
they can do, with greater or
Dose-response less strength, is to help us
concordance to make up our minds on
the fundamental question —
Temporal relationship is there any other way of
explaining the set of facts
Biological plausibility before us, is there any other
and coherence answer equally, or more,
likely than cause and
effect?‖ Hill (1965)
12/10/2012 31
32. Experimental Support for
MOA
Strength, consistency, specificity of association
What is the level of statistical and biological
significance for each event and for cancer?
Do independent studies and different
experimental hypothesis-testing approaches
produce the same associations?
Does the agent produce effects other than those
hypothesized?
Is the key event associated with precursor
lesions?
Section
2.4.3.2
12/10/2012 32
33. Experimental Support for
MOA
Dose Response Concordance
○ Is precursor induced at lower dose than
tumors?
○ If greater incidence of the precursor
occurs, does incidence of tumor
increase?
○ If the precursor event is more severe is
there an increase in tumor incidence?
12/10/2012 33
34. Experimental Support for
MOA
Temporal Relationship
○ Do the precursor events occur
before tumors are observed?
○ Is this observed in independent
studies?
12/10/2012 34
35. Mode of Action: Bladder Tumors, Key Events
Cytotoxicity and Regenerative Hyperplasia
DMAIII Measurable Key
Metabolite Events in Target Tissue
SEM
Urothelial
Toxicity
BrdU
Sustained BrdU Labeling
Labeling
Regenerative
Proliferation
Hyperplasia Tumor
37. Experimental Support for
MOA
Biological plausibility and coherence
○ Does the MOA make sense given what
is known about carcinogenesis in
general, and for the case specifically?
○ Are carcinogenic effects and events
consistent across structural analogues?
○ Is the database on the agent internally
consistent in supporting the MOA,
including relevant non-cancer
toxicities?
12/10/2012 37
38. Nuclear Receptor Workshop
Possible Key Strength Consistency Specificity Temporal Biological Biological Coherence Key Event
Events Reproducibility Gradient Plausibility (Causal)
Dose- Associated
Response (Marker?)
Modulatory
?
Neither
CAR activation High, Required High High Earliest Not Yes High Causal
for tumors1,2 2 In vivo Knock out event, in determine Fits in a (DWolf)
Bear in mind studies1,2 studies1,2 vivo and in d logical (RPeffer)
that both ref #1 In vitro nuclear vitro14 (any sequence (RBars)
& #2 involve translocation3,4 Perhaps data?) No (RSchoeny)
initiation with PB- data that I (CElcombe)
den and a induced am aware Causal, under
rather short activation of. the
period of of the Only in experimental
treatment with phosphatas vitro (93, conditions
pb, 32 wk in e that 58) outlined in
ref #1 & 30 wk appears to Ref #1 & #2
in ref #2, we facilitate (JGoodman)
do not know the
what would translocati
happen in car on of CAR
ko mice if they from the
were treated cytoplasm
with pb for 2 to the
years nucleus is
(JGoodman) the very
earliest
event?
12/10/2012 38
39. MOA/Human Relevancy ILSI/IPCS
NO
Is the weight of evidence Proceed with
sufficient to establish a mode risk assessment
of action (MOA) in animals?
YES
Can human relevancy of the MOA be
YES reasonably excluded on the basis of
MOA not fundamental, qualitative differences in
Relevant key events between
animals and humans?
NO
Can human relevancy of the MOA be
reasonably excluded on the basis of NO
YES
MOA not quantitative differences in either Proceed with
Relevant kinetic or dynamic factors between Risk assessment
animals and humans?
39
40. Concordance Analysis of Key Events:
Cytotoxic Mode of Action
Key Event Rodents Humans Concordance analysis
Presence of of key events is for
Yes Yes
metabolite the MOA and not
Persistent Yes Possible necessarily
cytototoxicity
chemical specific
Persistent Chemical specific and
regenerative Yes Possible
generic information
proliferation
relevant to adverse
Tumors Yes Possible outcome is useful
41. α2μ Globulin and Male Rat
Kidney Tumors
Chemical-
a2u-Globulin a2u -Globulin
"Complex"
Renal Reabsorption Renal Reabsorption
Nucleus Nucleus
Heterolysosome Amino Acids Heterolysosome
Circulation Circulation
42. α2u-Globulin
The main story
Protein produced by male rats
MOA– functional changes in epithelial cells of
proximal tubules
•Hyaline droplets accumulate
•Tubule cell degeneration
•Regenerative cell proliferation
•Expansion of initiated renal
tubule cells
12/10/2012 42
43. Human Relevance of α2u-globulin
nephropathy – U.S. EPA
Humans do not possess a protein that is similar to α2u in
abundance or binding characteristics; thus, humans would not
be at risk of developing a chemically induced protein-mediated
nephrotoxic response.
Borghoff SJ and Lagarde WH, Toxicol Appl Pharmacol. 1993 Apr;119(2):228-35.
If male rat kidney tumors develop
In the absence of female rat kidney tumors
Male rats have increased hyaline droplets
Hyaline droplets contain a2u-Globulin
Characteristic nephrotoxicity
The male rat kidney tumors are not relevant for human health
risk and would not be included in a risk assessment.
44. Is the MoA for phenobarbital plausible in
humans?
Key event in MoA Plausible in humans?
Activation of CAR
Induction of CYP2B Increase via CAR can occur
Hypertrophy Yes
Cell proliferation Not likely, based on in vitro
and in vivo data
Inhibition of apoptosis Possible but not likely, based on
limited in vitro data
Selective clonal expansion Possible but not likely, none reported
Occurrence of liver tumors No, based on
epidemiological data
45. Cancer Guidelines: What‘s
Different from 1986?
Analyze data before invoking default options.
Mode of action is key in decisions
Weight-of-evidence narrative replaces the
previous ―A-B-C-D-E‖ classification scheme.
Two step dose response assessment
Model in observed range
Extrapolate from point of departure
Consider linear and non-linear extrapolation
Address differential risks to children
12/10/2012 45
46. MOA and Kids
Supplemental Guidance for Assessing
Susceptibility from Early-Life Exposure
to Carcinogens
Effects observed in childhood
Early life exposures that contribute to later
life effects
MOA determines whether quantitative
adjustment is made
46
47. Supplemental Guidance
Use age-specific values for
exposure and potency
When data permit, develop
separate potency estimates
for childhood exposure
In risk characterization, mutagenic MOA risk
is increased by age-dependent adjustment
factor (used with exposure info for age
group)
○ <2 yrs old, 10 fold
○ 2 to < 16yrs, 3 fold
No MOA, linear extrapolation without ADAF;
non-linear MOA, no ADAF
47
48. Framework for Determining This may actually get
a Mutagenic Mode of published at some
Action for Carcinogenicity point in time
Using EPA‘s 2005 Cancer
Guidelines and Supplemental
Guidance for Assessing
Susceptibility from Early-Life
Exposure to Carcinogens
48
49. Framework on Default MOA
― It should also be noted that there is no
‗default MOA.‘ The Cancer Guidelines offer
some default procedures to use when no
MOA can be determined.‖
•No MOA is not the same as a Mutagenic MOA
Determination of mutagenic MOA is as
scientifically rigorous as any other MOA
I found nothing in IPCS on a default MOA
49
50. To boldly go where no regulatory
toxicologist has gone before . . .
Mutagenicity is the induction of permanent,
transmissible changes in the amount,
chemical properties, or structure of the
genetic material. These changes may involve a
single gene or gene segment, a block of genes, parts of
chromosomes, or whole chromosomes. Effects on whole
chromosomes may be structural and/or numerical (e.g.,
aberrations and/or aneuploidy).
50
50
12/10/2012
51. Boldly part 2
Genotoxicity is the induction of alterations to
genetic material. It is a broader term than
mutagenicity in that genotoxicity refers to potentially
harmful effects on genetic material, which are not
necessarily persistent and transmissible. Genotoxicity
may be mediated directly or indirectly by chemical or
physical agents, and may or may not be associated with
mutagenicity. Tests for genotoxicity include tests for
mutagenicity, as well as other tests which provide an
indication of induced damage to DNA. For example, such
tests may include unscheduled DNA synthesis (UDS),
sister chromatid exchange (SCE), mitotic recombination,
DNA adduct formation, or DNA strand breaks.
51
12/10/2012
52. What does this definition
do?
Distinguishes between genotoxic and
mutagenic (U.S. EPA Guidelines refer to
―mutagenic MOA‖; Europe deals with
genotoxic).
Includes numeric changes in chromosome
as mutagenic
But not likely to be linear at low dose
Includes agents that generate reactive
oxygen species (ROS)
But need to consider low dose response
52
53. Framework: Multi-step
Process
Risk assessment
is an iterative
process
Visualize the Framework as series of
linear steps
Assemble data
Assess, weigh data quality
WOE for mutagenicity
WOE for MOA
53
54. Step 2: Evaluate Data
Quality
Look at primary papers
Judge against current
acceptability criteria
Cites publications for evaluating quality (e.g.
Cimino 2006, OECD, ICH, IWGT, DHHS
2006)
Keep, but weigh
54
55. Step 3 Gene- tox Tests Measure
Different Events
Genotoxicity Assays
Mouse Chromosome Ames Bacterial
Type of Damage
Lymphoma Aberrations CHO cells Mutagenicity
Point mutation Yes No Yes
Oligonucleotide
insertion or deletion
Yes No Yes
Allele Loss Yes No No
Small Chromosome
alteration
Yes ? No
Large Chromosome
alteration
Yes Yes No
Aneuploidy ? Yes No
Adapted from M. Moore (2004)
Cancer Hazard ID TERA’s Dose-Response Assessment Boot Camp 55
55
56. Step 3: WOE for Mutagenic
Activity
Categorize data – suggest use of our table in
Appendix A.
Put in all data with notes on quality
Use consistent terms for assay types or
endpoints: positive, negative, inconclusive,
contradictory
Present summary of
database
56
57. Concen- Cytotoxicity Duration of Results With Results Without Conform to Ref
In vitro Assays trations observed Exposure metabolic metabolic relevant
Test System activation (+ S9) activation (- S9) guideline
Gene Mutation
Bacterial
Salmonella, reverse mutation
E. coli, reverse mutation
Mammalian
CHO gene mutation, hprt locus
Mouse L5178Y, tk locus
Chromosome
Mutation
Micronucleus assay
Chromosomal aberrations
DNA Effects
Mammalian
Unscheduled DNA synthesis
Sister chromatid exchanges
Comet assay
DNA adduct analysis
Lower Eukaryote
Saccharomyces cerevisiae, gene
conversion
57
58. WOE for Mutagenic Activity
Conclusions across endpoints: some
endpoints carry more weight than others
○ e.g. Sperm head morphology may be caused
by modification of protein structure
○ Morphologic cell transformation does not
measure mutation
WOE for mutagenic activity: negative, data
are inadequate, data are of questionable
quality, data are equivocal, data are positive
58
60. Data Preference: WOE Mutagenic MOA
Cancer-relevant oncogene or tumor suppressor gene
mutations detected in target tissue after chemical exposure.
Surrogate gene mutations detected in target tissue after
chemical exposure.
Chemical-specific DNA adducts (known to be mutagenic
adducts) in target tissue after chemical exposure.
Primary DNA damage in target tissue after chemical
exposure.
Gene mutations or chromosome aberrations in surrogate
tissues after in vivo exposure.
DNA adducts or other measures of DNA damage and/or
repair or in surrogate tissues after in vivo exposure.
Mutations, cytogentic damage, DNA adducts and/or primary
DNA damage in vitro.
60
12/10/2012
61. What Has a Mutagenic MOA?
Cyclophosphamide
Cytotoxic, alkylating
Alkylating
Cytotoxic
61
62. Source
Application to Levels of
Organization Based on
Source to Outcome
Environmental
Contaminant
Exposure
Molecular Initiating Event Cellular Effects Individual Population Community
Toxicity Pathway
Mode of Action
Adverse Outcome Pathway
Source to Outcome Pathway
62
63. Application to Levels of
Organization Based on Source
to Outcome
Source
Community
Environmental
Contaminant
Population
Exposure Individual
Molecular Initiating Event Cellular Effects
Toxicity Pathway
Mode of Action
Adverse Outcome Pathway
Source to Outcome Pathway
63
64. Cancer Guidelines: What‘s Different
from 1986?
Analyze data before invoking default options.
Mode of action is key in decisions
Weight-of-evidence narrative replaces the
previous ―A-B-C-D-E‖ classification scheme.
Two step dose response assessment
Model in observed range
Extrapolate from point of departure
Consider linear and non-linear extrapolation
Address differential risks to children
12/10/2012 64
66. Take home message
In science, data before defaults
Scientifically based low dose
extrapolation before defaults
Science may inform policy; policy should
never affect science
66
68. Two Step Approach
Model data in the
observed range – to a
R e s p o n s e (T u m o r o r N o n tu m o r D a ta )
it
o
n
D
o
se
)
point of departure
im
L
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Extrapolate below the
en
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E nv ironm e ntal d E m pirical
fi
at
n
E xpo sure Lev els C
o im
R ange of
st
of In terest 5% O b serv ation
lE
t9
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es
w
POD
en
o
(L
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x
x
1 0%
lt
fa u R ange of
r De
ea
L in E xtrapo lation
x x
0%
L E D 10 E D 10
UF x NOAEL
N on lin ear D efau lt
D o se x LOAEL
68
69. Extend the Observed Range Using
Precursor Data
Objective of choosing POD is to set it as
close to environmental levels as
Supported by data
Appropriate to model
Cancer Guidelines say precursor data
are useful for this
Must have MOA
Section
3.2.2
69
70. Cacodylic Acid: BMDs and BMDLs
Feeding Drinking water
10% 1% 10% 1%
Endpoint Duration Duration
BMD BMDL BMD BMDL BMD BMDL BMD BMDL
(mg/kg/d) (mg/kg/d) (mg/kg/d) (mg/kg/d) (mg/kg/d) (mg/kg/d) (mg/kg/d) (mg/kg/d)
104 104
Tumor weeks 7.74 5.96 6.80 2.22 weeks 1.92 1.21 0.88 0.14
10
weeks 1.36 1.04 0.42 0.32
104
Hyperplasia weeks 1.63 1.04 0.74 0.14
104
weeks 1.97 1.61 0.93 0.66
BrdU
10 weeks 0.65 0.29 0.54 0.07 Not determined. Available data not suitable for modeling.
labeling
3
weeks 0.68 0.18 0.31 0.02
Cytotoxicity No reliable dose-response data available
10 weeks 0.02 0.008 0.002 0.0007
70
71. Linear or Non-linear?
Two Step Dose Response Process
R e sp on se (Tum o r o r No n tu m o r D ata )
e)
os
D
on
it
Another Question First en
ce
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x x
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L E D 10 E D 10
UF x NOAEL
N on lin ear D efau lt
D ose x LOAEL
71
72. Is There Something Better?
Analyze the available data
Is there too much uncertainty or is
Invoke a
critical information lacking? Y default option*
N
Conduct risk assessment
72
73. Specify the sequence(s) of key
events
dosimetry Key event B1
Key event B2
Key event A1 Mode of
Action Assessment
endpoint
Key event A2
Key event A3
73
74. Source
Exposure
PBPK
Tissue dose
BBDR
Mode of action
Biologically Based
Dose Response
Model
Response
74
76. Reality check (I)
There are always data gaps
Arsenic
Formaldehyde
TCDD
phenobarbital
A BBDR model is a description of biological
structure with embedded empirical linkages
that cover the parts of the overall exposure-
dose-response linkage for which data are
missing.
76
77. Reality check (II)
As research improves our understanding of
the overall exposure-dose-response linkage,
the sophistication of the description of the
mode of action increases.
Corresponding iteration of the BBDR model
leads to more accurate predictions of dose-
response and time-course behaviors.
Will always be some degree of residual
uncertainty.
But is the default more uncertain?
77
78. And if no BBDR?
Two Step Dose Response Process
R e sp on se (Tum o r o r No n tu m o r D ata )
e)
os
D
on
it
m
Linear or Non-linear
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(L
(C
x
x
1 0%
lt
fa u
De R ange of
e ar
L in E x tra p o la tio n
x x
0%
L E D 10 E D 10
UF x NOAEL
N on lin ear D efau lt
D ose x LOAEL
78
79. Mutagenesis Paradigm
Mutagens/Spontaneous
DNA Damaged DNA
Damage Sensing
Cellular Response
DNA Repair Incorrect No repair
Repair/Replication
Repaired DNA Mutant DNA Dead Cell
Demarini 70
79
80. Threshold?
Demonstrated Based on MOA
By inspection of the Mutagenic MOA has
dose response been linear
curve But should consider
Fitting models and biology of mutation
checking goodness
of fit
Statistical tests for
one model or
another
Does mutagenic MOA
mean low dose linear?
BBDR should be first
choice 80
81. In vitro Mutation Dose-Response: MMS & MNU
Doak et al., 2007
HPRT MF
MMS
MMS
NOEL = 1 mg/ml
MNU
MNU
No NOEL
2011 EMS Annual Meeting Pottenger 81
82. In vitro Mutation Dose-Response:
ENU Johnson et al., 2009
HPRT MF
ENU threshold dose-response (Lutz & Lutz model)
Slide from Pottenger 82
83. Take Home Message
MOA informs dose response
assessment
DNA damage is not mutation
Mutation is not cancer
Some genotoxicity endpoints may be
reasonable biomarkers
May be useful for extending the lower end of
dose response curve
Useful in MOA
83
84. Take home message 2
In science, data before defaults
Scientifically based low dose
extrapolation before defaults
Science may inform policy; policy should
never affect science
84
86. NRC 2009 Silver Book 1
Framing questions
and design step.
Risk Assessment is
not an end in itself.
Characterize
uncertainty and
variability
Default before data?
These are strictly my own opinions
86
87. NRC 2009 Silver Book 2
Dose response
Additivity to background is a major theme
○ How differentiate between exogenous and
endogenous damage?
○ DNA adducts biomarkers, could have major role
○ Does this mean linear all the time?
EPA has expressed preference for BBDR
○ Low dose data for adduct formation
○ Low dose data for mutation
○ Low dose data for other markers
Again my own opinions
87
88. Breaking Down the Dichotomy
Cancer Non-Cancer
Threshold
Non-Threshold
Reversible
Irreversible
Safety Value
Risk value
RfD/RfC
Slope Factor
ADI/TDI
Unit Risk
MRL
Risk-Specific Dose
88
Notes de l'éditeur
May show in the amMake distinction between DA which is particular – to answer are DNA adducts causal. Not retro fitted risk assessments or dataThis is a pieces of the larger context for RA RMRisk assessment is not a linear process; one goes back and forth among the stepsOne size does not fit all; risk assessments should be designed to fit a purpose or purposesUnderstanding of available risk management options informs risk assessment planningStakeholder involvement will vary with assessment purpose, complexity, resourcesPeer review may be needed at several steps
I
Conceptual models are used to plan the risk assessment and associated data collection activities and are often revised periodically as data become available. They consist of two principal components: (1) a set of risk hypotheses that describe predicted relationships among stressor, exposure and health endpoint/response, along with the rationale for their selection; and (2) a diagram that illustrates the relationships presented in
Evaluate WOE across study but for a particular endpoint