Haber's rule duration adjustments should not be used systematically for risk assessment in public health decision-making

Sensory irritation and use of the best available science in setting exposure limits: Issues raised by a scientific panel review of formaldehyde human research studies

As a high production volume chemical with recognized sensory irritation and widespread exposure, the human health risk potential of formaldehyde has been reviewed by many international regulatory agencies and scientific advisory bodies. A scientific panel, the Human Studies Review Board, under the auspices of the EPA's Toxic Substances Control Act (TSCA) program recently reviewed the sensory irritation studies included in the 2022 Draft Integrated Risk Information System (IRIS) Formaldehyde Hazard Assessment in the context of their use in a weight of evidence evaluation of acute inhalation health effects. This panel issued a series of recommendations on the use of these studies for the purposes of calculating exposure limits (e.g., study design preferences; uncertainty adjustment). Considering that these recommendations might reflect topic areas with varying degrees of scientific consensus, this commentary reflects on commonalities and distinctions amongst international formaldehyde exposure limits based on sensory irritation. Notably, each review panel charged with an assessment of the science recommended that no adjustment was needed to account for either exposure duration or human variability. These areas of scientific consensus should be considered as the best available science for the purposes of setting exposure limits in the anticipated TSCA Risk Evaluation on formaldehyde.

Spaceflight Maximum Allowable Concentrations for Ethyl Acetate

INTRODUCTION: Ethyl acetate is a simple organic compound that occurs naturally and is used industrially as a solvent. It has been detected in the ISS atmosphere and is known to off-gas from building materials. As NASA astronauts have been and will be exposed to ethyl acetate during space missions, Spaceflight Maximum Allowable Concentrations (SMACs) were developed following an extensive review of the available literature.METHODS: Toxicological data relevant to SMAC development was collected from electronic databases using principles of systematic review, and from previous assessments and reviews of ethyl acetate.RESULTS: From an initial pool of over 35,000 studies, 10 were identified as studies appropriate to support SMAC development. The toxicological properties of ethyl acetate are relatively straightforward. Ethyl acetate is rapidly absorbed and converted by carboxyesterases to ethanol. At concentrations on the order of 400 ppm for 4-8 h, most volunteers experienced mild irritation but no lasting effects. In subchronic animal studies, mild sedative effects and changes in body weight and weight gain were observed at 750 ppm and above.DISCUSSION: Numerous studies were identified to support the development of both short- and long-duration SMACs. No chronic studies were available, but the high quality of the subchronic studies and the short half-life of ethyl acetate support extrapolation to longer durations.Williams ES, Ryder VE. Spaceflight maximum allowable concentrations for ethyl acetate. Aerosp Med Hum Perform. 2023; 94(1):25-33.

14-Day Nose-Only Inhalation Toxicity and Haber's Rule Study of NNK in Sprague-Dawley Rats

4-(Methylnitrosamino)-1-(3-pyridyl)-1-butanone (NNK) is one of the key tobacco-specific nitrosamines that plays an important role in human lung carcinogenesis. However, repeated inhalation toxicity data on NNK, which is more directly relevant to cigarette smoking, are currently limited. In the present study, the subacute inhalation toxicity of NNK was evaluated in Sprague Dawley rats. Both sexes (9-10 weeks age; 16 rats/sex/group) were exposed by nose-only inhalation to air, vehicle control (75% propylene glycol), or 0.8, 3.2, 12.5, or 50 mg/kg body weight (BW)/day of NNK (NNK aerosol concentrations: 0, 0, 0.03, 0.11, 0.41, or 1.65 mg/L air) for 1 hour/day for 14 consecutive days. Toxicity was evaluated by assessing body and organ weights; food consumption; clinical pathology; histopathology observations; blood, urine, and tissue levels of NNK, its major metabolite 4-(methylnitrosamino)-1-(3-pyridyl)-1-butanol (NNAL), and their glucuronides (reported as total NNK, tNNK, and total NNAL, tNNAL, respectively); O6-methylguanine DNA adduct formation; and blood and bone marrow micronucleus frequency. Whether the subacute inhalation toxicity of NNK followed Haber's Rule was also determined using additional animals exposed 4 hours/day. The results showed that NNK exposure caused multiple significant adverse effects, with the most sensitive endpoint being non-neoplastic histopathological lesions in the nose. The lowest-observed-adverse-effect level (LOAEL) was 0.8 mg/kg BW/day or 0.03 mg/L air for 1 hour/day for both sexes. An assessment of Haber's Rule indicated that 14-day inhalation exposure to the same dose at a lower concentration of NNK aerosol for a longer time (4 hours daily) resulted in greater adverse effects than exposure to a higher concentration of NNK aerosol for a shorter time (1 hour daily).

Phosgene: toxicology, animal models, and medical countermeasures

Phosgene is a gas crucial to industrial chemical processes with widespread production (∼1 million tons/year in the USA, 8.5 million tons/year worldwide). Phosgene's high toxicity and physical properties resulted in its use as a chemical warfare agent during the First World War with a designation of CG ('Choky Gas'). The industrial availability of phosgene makes it a compound of concern as a weapon of mass destruction by terrorist organizations. The hydrophobicity of phosgene exacerbates its toxicity often resulting in a delayed toxidrome as the upper airways are moderately irritated; by the time symptoms appear, significant damage has occurred. As the standard of care for phosgene intoxication is supportive therapy, a pressing need for effective therapeutics and treatment regimens exists. Proposed toxicity mechanisms for phosgene based on human and animal exposures are discussed. Whereas intermediary components in the phosgene intoxication pathways are under continued discussion, generation of reactive oxygen species and oxidative stress is a common factor. As animal models are required for the study of phosgene and for FDA approval via the Animal Rule; the status of existing models and their adherence to Haber's Rule is discussed. Finally, we review the continued search for efficacious therapeutics for phosgene intoxication; and present a rapid post-exposure response that places exogenous human heat shock protein 72, in the form of a cell-penetrating fusion protein (Fv-HSP72), into lung tissues to combat apoptosis resulting from oxidative stress. Despite significant progress, additional work is required to advance effective therapeutics for acute phosgene exposure.

Risk assessment of components in tobacco smoke and e-cigarette aerosols: a pragmatic choice of dose metrics

BACKGROUND

Risk assessment of individual tobacco smoke components is important for the purpose of prioritization or selecting chemicals for monitoring products. Smoking is characterized by a highly varying, intermittent exposure and the challenge is to choose the most appropriate dose metric.

METHODS

Generally, average daily exposure estimates are used as dose metric, without considering temporal determinants. The applicability hereof is discussed in the context of choosing dose metrics for local respiratory tract effects and for systemic effects in a smoking scenario or for the use of e-cigarettes.

RESULTS

Using average daily exposure estimates for the smoking scenario can lead to erroneous risk evaluations for several reasons. Inhaled peak air concentrations during a puff can be two to three orders of magnitude higher than the calculated average daily inhaled concentration, which may impact the assessment of both systemic and local health effects. A pragmatic risk assessment is proposed, based on the Margin of Exposure (MoE) approach. The choice of an appropriate dose metric, such as inhaled concentration, inhaled dose or absorbed dose, depends on the type of effect. Temporal characteristics should be considered in the final step of the MoE approach, as is illustrated by two cases, glycerol and benzene.

CONCLUSION

The choice of an appropriate dose metric and inclusion of temporal determinants are important aspects in the risk assessment of individual smoke components. The proposed MoE approach provides the opportunity to weigh smoking-related exposure characteristics during the final step of the risk evaluation.

Nonlinear dose-time-response functions and health-protective exposure limits for inflammation-mediated diseases

Why have occupational safety regulations in the United States not been more successful in protecting worker health from mesothelioma risks, while apparently succeeding relatively well in reducing silicosis risks? This paper briefly discusses biological bases for thresholds and nonlinearities in exposure-response functions for respirable crystalline silica (RCS) and asbestos, based on modeling a chronic inflammation mode of action (mediated by activation of the NLRP3 inflammasome, for both RCS and asbestos). It applies previously published physiologically based pharmacokinetic (PBPK) models to perform computational experiments illuminating how different time courses of exposure with the same time-weighted average (TWA) concentration affect internal doses in target tissues (lung for RCS and mesothelium for asbestos). Key conclusions are that (i) For RCS, but not asbestos, limiting average (TWA) exposure concentrations also tightly constrains internal doses and ability to trigger chronic inflammation and resulting increases in disease risks (ii) For asbestos, excursions (i.e., spikes in concentrations); and especially the times between them are crucial drivers of internal doses and time until chronic inflammation; and hence (iii) These dynamic aspects of exposure, which are not addressed by current occupational safety regulations, should be constrained to better protect worker health. Adjusting permissible average exposure concentration limits (PELs) and daily excursion limits (ELs) is predicted to have little impact on reducing mesothelioma risks, but increasing the number of days between successive excursions is predicted to be relatively effective in reducing worker risks, even if it has little or no impact on TWA average concentrations.

Development of an acute, short-term exposure model for phosgene

Phosgene is classified as a chemical warfare agent, yet data on its short-duration high concentration toxicity in a nose-only exposure rat model is sparse and inconsistent. Hence, an exposure system for short-term/high concentration exposure was developed and characterized. Herein, we report the median lethal concentration (LC₅₀) for a 10-min nasal exposure of phosgene in a 24-h rat survival model. Male Wistar rats (Envigo) weighing 180-210 g on the day of exposure, were exposed to phosgene gas via nose-only inhalation using a system specifically designed to allow the simultaneous exposure and quantification of phosgene. After 24 h, the surviving rats were euthanized, the lung/body mass ratio determined, and lung tissues analyzed for histopathology. Increased terminal airway edema in the lungs located primarily at the alveoli (resulting in an increased lung/body mass ratio) coincided with the observed mortality. An LC₅₀ value of 129.2 mg/m³ for a 10-min exposure was determined. Furthermore, in agreement with other highly toxic compounds, this study reveals a LC₅₀ concentration value supportive of a nonlinear toxic load model, where the toxic load exponent is >1 (n_e = 1.17). Thus, in line with other chemical warfare agents, phosgene toxicity is predicted to be more severe with short-duration, high-concentration exposures than long-duration, low-concentration exposures. This model is anticipated to be refined and developed to screen novel therapeutics against relevant short-term high concentration phosgene exposures expected from a terrorist attack, battlefield deployment, or industrial accident.

A comparison of Reduced Life Expectancy (RLE) model with Haber's Rule to describe effects of exposure time on toxicity

The Reduced Life Expectancy (RLE) Model (LC50 = [ln(NLE) - ln(LT50)]/d) has been proposed as an alternative to Haber's Rule. The model is based on a linear relationship between LC50 (Lethal Exposure Concentration) and lnLT50 (Lethal Exposure Time) and uses NLE (Normal Life Expectancy) as a limiting point as well as a long term data point (where d is a constant). The purposes of this paper were to compare the RLE Model with Haber's Rule with available toxicity data and to evaluate the strengths and weaknesses of each approach. When LT50 is relatively short and LC50 is high, Haber's Rule is consistent with the RLE model. But the difference between the two was evident in the situation when LT50 is relatively long and LC50 is low where the RLE model is a marked departure from Haber's Rule. The RLE Model can be used to appropriately evaluate long term effects of exposure.

Recognizing the importance of exposure-dose-response dynamics for ecotoxicity assessment: nitrofurazone-induced antioxidase activity and mRNA expression in model protozoan Euplotes vannus

The equivocality of dose-response relationships has, in practice, hampered the application of biomarkers as a means to evaluate environmental risk, yet this important issue has not yet been fully recognized or explored. This paper evaluates the potential of antioxidant enzymes in the ciliated protozoan Euplotes vannus for use as biomarkers. Dose-response dynamics, together with both the enzyme activity and the gene expression of the antioxidant enzymes, superoxide dismutase, and glutathione peroxidase, were investigated when E. vannus were exposed to graded doses of nitrofurazone for several discrete durations. Mathematical models were explored to characterize the dose-response profiles and, specifically, to identify any equivocality in terms of endpoint. Significant differences were found in both enzyme activity and messenger RNA (mRNA) expression in the E. vannus treated with nitrofurazone, and the interactions between exposure dosage and duration were significant. Correlations between enzyme activity, mRNA expression, and nitrofurazone dose varied with exposure duration. Particularly, the dose-responses showed different dynamics depending on either endpoint or exposure duration. Our findings suggest that both the enzyme activity and the gene expression of the tested antioxidant enzymes can be used as biomarkers for ecotoxicological assessment on the premise of ascertaining appropriate dosage scope, exposure duration, endpoint, etc., which can be achieved by using dose-response dynamics.

Glyceria maxima as new test species for the EU risk assessment for herbicides: a microcosm study

In its recent guidance document on tiered risk assessment for plant protection products for aquatic organisms, the European Food Safety Authority (EFSA) proposed to use Glyceria maxima as monocotyledonous grass species for the testing of special herbicide groups. However, published toxicity data for this species is very limited and there is no test guideline for Glyceria sp. For this reason a microcosm study was conducted in order to gain experience on the degree of sensitivity of G. maxima to the herbicidal substances clodinafop-propargyl (grass herbicide) and fluroxypyr (auxin) in comparison to the already established test organism water milfoil Myriophyllum spicatum and the duckweed species Landoltia punctata. Five concentrations without replicates were tested for each test substance using 10 microcosms and three microcosms served as controls. The experiment was run for 8 weeks. Morphological endpoints were used to determine growth and EC50 values. The results show that M. spicatum was most sensitive to fluroxypyr (37 days EC50 for roots: 62 µg/L) and G. maxima most sensitive to clodinafop-propargyl (22 days EC50 for total shoot length: 48 µg/L) whereas the duckweed species was considerable less sensitive. Hence, G. maxima turns out to be a good candidate for testing grass specific herbicides, supporting its inclusion as an additional macrophyte test for the risk assessment of herbicides as proposed by the EFSA.

Heuristics structure and pervade formal risk assessment

Lay perceptions of risk appear rooted more in heuristics than in reason. A major concern of the risk regulation literature is that such "error-strewn" perceptions may be replicated in policy, as governments respond to the (mis)fears of the citizenry. This has led many to advocate a relatively technocratic approach to regulating risk, characterized by high reliance on formal risk and cost-benefit analysis. However, through two studies of chemicals regulation, we show that the formal assessment of risk is pervaded by its own set of heuristics. These include rules to categorize potential threats, define what constitutes valid data, guide causal inference, and to select and apply formal models. Some of these heuristics lay claim to theoretical or empirical justifications, others are more back-of-the-envelope calculations, while still more purport not to reflect some truth but simply to constrain discretion or perform a desk-clearing function. These heuristics can be understood as a way of authenticating or formalizing risk assessment as a scientific practice, representing a series of rules for bounding problems, collecting data, and interpreting evidence (a methodology). Heuristics are indispensable elements of induction. And so they are not problematic per se, but they can become so when treated as laws rather than as contingent and provisional rules. Pitfalls include the potential for systematic error, masking uncertainties, strategic manipulation, and entrenchment. Our central claim is that by studying the rules of risk assessment qua rules, we develop a novel representation of the methods, conventions, and biases of the prior art.

Application of the threshold of toxicological concern concept when applied to pharmaceutical manufacturing operations intended for short-term clinical trials

In the manufacture of pharmaceuticals, if a multiproduct facility shares equipment amongst drug substances/products it is incumbent upon the manufacturer to demonstrate removal of the pharmaceutical through a robust cleaning validation/verification program. Removal must be to below limits considered acceptable from a quality and toxicological perspective. In order to address the toxicological concerns, an acceptable daily exposure (ADE) was developed which is the "dose that is unlikely to cause an adverse effect if...exposed, by any route...at or below this dose every day for a lifetime" (ISPE, 2010). For compounds in development, defaulted ADEs were proposed by Dolan et al. (2005) and adopted by the International Society of Pharmaceutical Engineers (ISPE) as conservative cutoffs for compounds with limited data. In Phase 1 clinical trials, exposure is typically short-term (single dose or repeated doses for ≤30 days) compared to the chronic doses used to derive ADE and defaulted ADEs. An analysis of publicly available databases for toxicological and pharmacological effects supports the use of 10-fold higher defaulted values when the residual drug substance is in a developmental pharmaceutical intended for Phase 1 clinical trials (exposure ≤30 days).