When to Perform and Who Performs
Quantitative Exposure Assessments?
ACA's
Screening Level Evaluation Process
Consultants
Other Key Organizations
Those Willing to Learn
ACA's Screening Level
Evaluation Process
ACA has drafted a process for evaluating screening level
exposure with the basic elements shown in the following
outline. The ACA recognizes that there are many considerations
that must be a part of this decisionmaking process, and
these may vary significantly from one situation to another.
These will certainly need further discussion and elaboration
as the HPV program moves forward, in cooperation with sponsors
and other stakeholders.
1. Understanding how a specific chemical
flows through commerce. ...from chemical manufacturing,
through distribution, handling, processing, end products,
and release to the environment.
2. Determining the key routes by which
a chemical might reach the public or the environment, including:
- Occupational and Community exposures
at industrial facilities where HPV chemicals are either
manufactured, handled, or processed;
- Product-related exposures where an
HPV chemical is an ingredient. Consistent with the U.
S. EPA's PMN framework, this includes sub-sets of industrial
(e.g., a degreaser for cleaning machine tool parts), commercial/institutional
(e.g., janitorial products), or consumer (e.g., household
products) applications; and
- Other exposures, such as when HPV
chemicals are released to the environment from industrial
facilities or product disposal in ways that may reach
humans (e.g., via drinking water or food), or natural
sources of a chemical.
3. Estimating key exposures, using available
predictive models and/or direct observations such as monitoring
data. This step may also include assessing the potential
for aggregate exposures (where an individual or the environment
might be exposed simultaneously to the same chemical through
several pathways). Consistent with the screening-level nature
of the evaluation, work is focused on estimating key exposures
for the above routes, based on predictive models and/or
available direct observations (e.g., monitoring data). Where
appropriate, the results from individual routes of exposure
can also be used to estimate aggregate exposures for multi-purpose/multi-use
chemicals.
4. Comparing exposures to relevant hazard
data. The comparison of exposure to hazards may involve,
for example, estimating margins of exposure (i.e., the ratio
of exposure to a threshold for adverse effects). Such a
calculation is often used as a surrogate for the potential
of a chemical to cause harm.
5. Evaluating whether a chemical is sufficiently
studied, or there is a need for further action. This typically
involves a weight-of-evidence approach that takes into account
the uncertainties associated with both the hazard and exposure
analysis, severity of the potential harm, reliability of
numerical estimates, etc... Four basic options are included:
- An early conclusion, after identifying
the potential pathways for exposure, that there is either
very limited or no potential for exposure based on how
or where a chemical is used, or that the chemical is widely
recognized as being a low level hazard for a particular
pathway. As a result, the chemical can viewed as sufficiently
studied, based on a qualitative analysis.
- Chemicals/exposure pathways that are
viewed as sufficiently studied, based on a qualitative
or quantitative screening level comparison of potential
exposures to applicable hazards.
- Chemicals/pathways that need further
work based on a screening level analysis. This recognizes
that many screening level approaches for estimating either
exposures or hazard are inherently conservative, and may
overestimate their respective endpoints. Thus, when the
difference between exposure and hazard thresholds is small,
a more comprehensive and accurate analysis may be needed
for to determine whether the margins are meaningful, or
simply due to the conservativeness of the screening data.
Further work may include collecting more complete use
and exposure information, or using more sophisticated
and accurate "higher tier" exposure analysis or hazard
evaluations.
- Chemicals/pathways that indicate the
need for management, where a screening level evaluation
indicates that exposures are significant relative to the
hazards, and sufficiently well understood, after considering
uncertainties, severity of effects, etc...
Consultants
Disclaimer: Mention of specific consultants and consulting
organizations is not intended to imply an endorsement of
their use by the Alliance for Chemical Awareness nor is
it intended to be considered a complete listing of consultants
or consulting organizations. Persons considering use of
a particular consultant or consulting organization, whether
on this list or not, needs to conduct their own investigation
of the technical merits and other factors associated with
that consultant or consulting organization.
In addition to possible use of the above
Internet Mailing Lists, the Web sites, membership directories,
and journals of key professional societies are useful resources.
These societies include the International Society of Exposure
Analysis (ISEA: www.iseaweb.org/)
and the Society for Risk Analysis (SRA: www.sra.org/).
Also, RiskWorld (www.riskworld.com)
has an "Consultants, Environment, Health & Safety" section,
ToxicologyOnline.com is a Web site with a Business Directory
section listing some consultants, and the Consultants Alley
(www.consultantsonline.org/gateway.htm)
has an "Environmental Consultants" section.
Further, trade associations and professional
colleagues may be able to share the names of consultants
and consulting companies they have used or considered. For
example, some possible consultants and consulting companies
include (see disclaimer above, and consultants not currently
listed should feel free to contact the Alliance for Chemical
Awareness to be listed below):
- AMEC Earth & Environmental Limited
E-mail: Ipanek@agraee.com
- CANTOX www.cantox.com/
- Charles Yoe, Ph.D. E-mail: cyoe1@home.com
- Consultants in Toxicology, Risk Assessment
and Product Safety (CTRAPS) www.ctraps.com
- ENVIRON www.environcorp.com/
- Environmental Health & Safety, Inc.
and Bergeson & Campbell, P.C. E-mail: EHSIncMI@aol.com
- Environmental Standards, Inc. (Robert
Fares) Phone: 703-444-4976
- Exponent www.exponent.com/home.html
- Gradient Corporation www.gradcorp.com/
- Health Risk Solutions, LLC Chuckaxten@aol.com
- Health & Environmental
Safety Alliance www.HESAONLINE.com
- ICF Consulting www.icfconsulting.com
- Infoscientific.com www.Infoscientific.com
- McLaren/Hart, Inc. E-mail: www.mclaren-hart.com/services/Services.html
- Notox Safety & Environmental Research
E-mail: notox@knoware.nl
- Novigen Sciences, Inc. www.novigensci.com/
- Sciences International, Inc. E-mail:
rreiss@sciences.com
- The Sapphire GroupT www.TheSapphireGroup.com
- The Weinberg Group, Inc. www.weinberggroup.com/
- Whitmyre Residential Research, LLC
www.wresres.com
Finally, the following book may be of
interest (also available via the World Wide Web as part
of Gale Business Resources' GaleNet at
http://www.galenet.com/:
"Consultants & Consulting Organizations
Directory"
The Gale Group
27500 Drake Road
Farmington Hills, MI 48331-3535
Phone: 800-457-4253 (International: 248-699-4253).
Fax: 248-699-8064
Other Key Organization
American Chemistry Council (formerly the Chemical Manufacturers
Association)
In the summer of 1997, as part of the
planning for the ACC Long-Range Research Initiative (LRI),
State of the Science (STOTS) White Papers were prepared
to identify the issues and the research needs associated
with exposure assessment and other topics. In the fall of
1997, a large workshop of scientists was assembled in Research
Triangle Park, NC for the expressed purpose of outlining
the State of the Science (STOTS) program. As part of this
effort, two polls of the member-companies were conducted
to rate and rank the most important research issues impacting
the chemical industry. In both polls understanding and quantifying
the actual levels of chemical exposure to humans in the
real world was ranked as the top issue.
Following the implied mandate from these polls, the Human
Health Exposure Assessment Technical Implementation Panel
(HHEA TIP) was formed in 1998. The goal from the beginning
was to assemble a diverse group of exposure assessment professionals
from different backgrounds and organizations. All the members
bring experience in real life exposure and risk assessments
to chemicals used in agriculture, consumer products, occupational,
and public settings. In order to assure an open and diversified
process, participants external to the chemical industry
were also identified and added to the TIP. These included
members from U.S. EPA, universities, Chemical Industry Institute
of Toxicology (CIIT), and independent consultants in the
exposure assessment field. At least one member has ties
to the environmental activist community along with being
both an outstanding scientist and an active environmentalist.
In order to move the program forward three outstanding consultants
with expertise in complimentary areas of exposure assessment
were initially added to the TIP as full members and, as
of late 2000, are still available "as needed" for specific
TIP efforts relevant to their individual areas of expertise
.
To get the TIP started in the right direction, two workshops
were organized to solicit feedback from ACC member companies
and from scientific experts in exposure assessment. For
the first workshop, conducted in the fall of 1998, representatives
from all ACC member companies were invited to come share
the needs and concerns they had in the area of exposure
assessment. Three areas were identified as the highest priorities
for research:
MICROENVIRONMENTAL MODELING
DEMOGRAPHICS and DATABASES
DERMAL AND ORAL BIOAVAILABILITY
This workshop was followed in the spring of 1999 with a second
workshop where more than 30 experts, actively engaged in exposure
assessment research, were invited to identify specific research
topics that could be selected for the research program. The
workshop provided an excellent sounding board and technical
discussion, but only partially narrowed the possible range
of topics that the research program could address. In fact,
the discussions added even more potential topics for consideration.
Unable to identify a short list of research needs, the group
came to the following conclusions:
- The science of human exposure assessment is currently
inadequate for cost-effective risk-based health evaluations.
- There is no overall scoping vision available to define
human exposure assessment research needs.
- Research needs appear to be much larger than the amount
of money being allocated.
- Prioritization is absolutely necessary to render the
most value in the shortest time.
Then, after two days of discussion, the experts unanimously
recommended that the TIP commission and publish critical review
papers on the current status of the science in four topic
areas that would identify and prioritize gaps for further
research:
1. Microenvironmental Models 2. Exposure Demographics
3. Dermal and Oral Availability 4. Comprehensive Chemical
Exposure Model
The Exposure TIP followed the advice of the scientific
experts and prepared and distributed Requests for Proposals
(RFPs) for the first three topics at the end of 1999. Contracts
for the first three were let in the spring of 2000 with
completion in early 2001. An RFP for the fourth topic was
distributed for bid in May, 2000 and was awarded in late
2000. The TIP will use the output from these projects to
form the basis for how the TIP moves forward for at least
the next three years, including the formulation and prioritization
of the TIP's research plan.
Also, some other projects have been identified that are
clearly worthwhile, and they are being funded in the context
of the Research Management Plan as developed by the SST.
These are projects that rate a high priority in fulfilling
the mission of the TIP, which is:
Identify, facilitate, and communicate generic research
that will characterize people's exposure to chemicals and
raise the confidence and lower the uncertainty for quantitative
estimates of exposure associated with potential human health
effects to chemicals.
The projects currently being funded include :
- Study of Worker Soil Ingestion by Dr. Ed Calabrese
(University of Massachusetts).
- Joint funding with the European Chemical Industry Council
(CEFIC) to improve the EASE model.
The American Chemistry Council public Web site is:
www.americanchemistry.com
American Crop Protection Association (ACPA)
Organized in 1933, ACPA is the not-for-profit
trade organization representing the major manufacturers,
formulators and distributors of crop protection and pest
control products, including biotechnology products with
crop production and protection characteristics. ACPA member
companies produce, sell and distribute virtually all the
active compounds used in crop protection chemicals registered
for use in the United States. The ACPA Web site is:
www.acpa.org/
(The late) American Industrial Health Council (AIHC)
AIHC's Exposure Assessment's Program
Team Exposure's Initiative in early 2000 developed a case
study set. The purpose was to prepare aggregate human exposure
estimates and risk assessments for a set of five High Production
Volume (HPV) chemicals, and to demonstrate the scope of
available exposure information from chemical producers and
users. The five compounds were selected to represent a variety
of chemical types, product applications, exposure routes,
and processes.
American Industrial Hygiene Association's (AIHA) Risk
Assessment Committee
The American Industrial Hygiene Association
Risk Assessment Committee was formed to further AIHA's national
presence in risk assessment and to promote the growth and
development of risk assessment expertise within the industrial
hygiene profession. The committee's goal is to assemble,
evaluate, and disseminate information on risk assessment
issues, positions, science, and technology to industrial
hygienists and other interested groups. The risk assessment
committee sponsors symposiums, forums, and professional
development courses to further educate and inform interested
parties on the latest risk assessment methodology. The AIHA
web site is:
www.aiha.org/committe/risk.html.
Chemical Specialties Manufacturers Association (CSMA)
CSMA's Residential Exposure Joint Venture
Project has a novel survey instrument for collecting temporal
product use information. The current orientation is on pesticide
products.
Health and Environmental Risk Assessment (HERA)
Initiative of AISE (the European association
of the cleaning, detergent, maintenance, and soap product
industries) and CEFIC started in 1999. A goal is to demonstrate
that targeted risk assessment provides relevant safety information
on detergent ingredients and products to regulators and
the public in a fast and effective way. Other goals are
to contribute to risk-based approach in European Union (EU)
chemicals legislation, and to serve as a pilot for targeted
risk assessment in other sectors and/or geographies.
Non-Dietary Exposure Task Force (NDETF)
This is a U.S. Food Quality Protection
Act- (FQPA-) related effort for pesticides, including: 1)
regulatory strategy for registration and re-registration,
2) evaluation of toxicological data, 3) screening-level
dietary exposures and risk assessments, 4) screening-level
and refined (Monte Carlo) nondietary exposures/risk assessments
for indoor and outdoor residential uses, 5) design and implementation
of an exposure monitoring program in simulated residential
environments to measure dislodgeable residues, dissipation
of airborne levels over time, biomonitoring in adult volunteers
exposed to treated surfaces through normal contact activities,
and a variety of satellite studies (e.g., collection of
time-activity data for children), and 6) development of
aggregate risk estimates.
Organisation for Economic Co-operation and Development's
(OECD's) Work on Chemical Risk Management ("preventing,
controlling, and reducing risks posed by chemicals"). Web
site URL:
http://www.oecd.org/ehs/risk.htm
"The ultimate aim of the testing and assessment of chemicals
is to prevent or manage undue risks. The core objective
of OECD's work on risk management is to support Member countries'
efforts to develop national policies and actions, and, where
appropriate, to develop and implement international risk
management measures. In support of this objective, the OECD
Risk Management Programme focuses on two areas: (1) developing
methods and technical tools that can be used by OECD and
Member countries to enhance their current risk management
programmes; and (2) identifying specific chemical exposures
of concern in Member countries and evaluating possible risk
management opportunities."
Of key interest to ACA efforts is OECD's
"Providing Tools to Screen out Chemicals Harmful to Man
and the Environment during the Research and Development
Stage" effort. Quoting from OECD's Web site, "The aim
of this initiative is to help identify, during a company's
development stage when new chemicals are designed, those
products that may pose a risk to man or the environment.
The results of this work should lead to a reduction in
the number of problematic chemicals entering new chemical
review programmes, and a reduction in expenditures by
companies on products that may never enter the marketplace.
The main objectives of this initiative are (1) the collection
of information on models, tools and other analytical methods
used for screening new chemicals; (2) indexing and analysing
this material; and (3) publishing the results on the Internet
along with links to tools that are available on-line."
This collection of information is in progress, and the
results will be reviewed to help insure all useful exposure
assessment software programs are included in the ACA's
Web site collection, with appropriate links provided to
OECD and non-OECD Web site information.
Outdoor Residential Exposure Task Force (ORETF)
The Outdoor Residential Exposure Task
Force (ORETF) is a consortium of 33 member companies that
have joined in response to a data call-in on exposure information
for individuals reentering residential lawns that have been
treated with pesticides. Its objectives include developing
generic data to evaluate human exposures resulting from
pesticide use on residential turf (mixer/loader and applicator
exposure, and re-entry exposure to treated turf). Another
objective is to determine exposures to pesticides used in
home vegetable gardens and ornamentals. An example of an
ORETF sponsored project is one to assess human activities
on residential lawns with respect to incorporation of time-activity
data for assessing post-application exposures to residential
turf chemicals. Stanford University exposure experts have
conducted videotaping to quantify the frequency and duration
of specific time-activity data for children, including frequency
of contact with surfaces and frequency of hand-to-mouth
activities for assessing incidental oral ingestion exposures.
The object of this effort is to develop a protocol for specific
structured exercise or activity regimens on turf to simulate
the contact with treated turf for each specific age group,
which can then be used as a basis for exposure assessment.
Other ORETF activities include analysis of pesticide turf-to-skin
transfer factors, measurement of dermal and inhalation exposures
to home pesticides during use, and the collection of survey
information on the residential use and application of outdoor
pesticides.
Synthetic Organic Chemical Manufacturers Association
(SOCMA)
SOCMA, "The Association for the
Batch & Custom Chemical Industry," is the not-for-profit
trade organization representing the interests of more than
300 member companies. The SOCMA Web site is: www.socma.com
World Heath Organization
(WHO), International Programme for Chemical Safety (IPCS)
The IPCS's working group on exposure
modeling is developing a "Principles of Characterizing and
Applying Human Exposure Models" document. The main contact
is Dr. Otto Hänninen (otto.hanninen@ktl.fi). The document
currently includes an Introduction, followed by sections
on Principles of Exposure Modeling, Exposure (and Dose)
Model Types and Model Components, Model Applicability, Recommendations,
and Literature. "Short introduction to exposure models presented
in scientific literature is given. The focus of this background
paper, however, is more on discussing properties of exposure
models and how they should be described in order to help
model users in selecting and applying the most appropriate
models for the different exposure estimation tasks." Also,
IPCS has developed an extensive exposure-related glossary
available via its "harmonization" Web site; however, this
information is currently password protected. The IPCS Web
site is: http://www.ipcsharmonize.org