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°1353

Author

Barnes, Donald G.

Corporate Author
Report/Article TltlO Memorandum: FDA Risk Assessment for Higher
Chlorinated Dibenzo-p-dioxins, from Donald G. Barnes
to Alvin Young and others, May 13, 1983

Journal/Book Title
Year

0000

Month/Day
Color

D

Number of limps 21
DeSCTlptOn Notes

Includes as an attachment this article: "The Use of
Epidemiology in the Regulation of Dioxins in Food
Supply," Regulatory Toxicology and Pharmacology, 1,
379-387(1981).

Thursday, May 03, 2001

Page 1353 of 1403

�UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
tp

WASHINGTON, D.C. 20460

&lt;

1 3 1983
OFFICE OF
PESTICIDES AND TOXIC SUBSTANCES

MEMORANDUM

TO:

Addressees

SUBJECT:

FDA Risk Assessment for Higher Chlorinated
Dibenzo-p-dioxins

Attached is a recently prepared risk assessment by the
Food and Drug Administration for hexa-, hepta- and octachlorodibenzo-p-dioxins in chicken eggs.
I believe the analysis presented here is an interesting
one and could provide fodder for a future first Friday feed.

Donald G. Barnes, Ph.D.
Senior Science Advisor to the
Assistant Administrator
for Pesticidees
and Toxi-'C, .Sujsst-.ances
Attachment
Addressees :
Lisa Barrera
Pat Roberts
Judy Bellin
David Vanormer
Priscilla Holtzclaw
Bob McGaughy
(/Al Young
Carl Keller

A-101
'-'
A-132
WH-565
TS-769C
WH-548D
RD-689
f
Veterans Adm. &lt;£— T4
NIEHS

�DEPARTMENT OF HEALTH &amp; HUMAN SERVICES

Public Health Service

Memorandum
Date

April 29, 1983

Prom

Acting Chief, Contaminants &amp; Natural Toxicants Evaluation Branch (HFF-159)

Subject

Levels of Concern for Hexa- (HCDD), Hepta- (HpCDD) and
Octachlorodibenzo-p-dioxins (XDD) in Chicken and Eggs

To

Mr. John Taylor
Director, Division of
Guidance (HFF-310)
Through: Dr. Gary Flamm
Acting, Associate Director for Toxicological Sciences (HFF-100)
As a result of concerns for higher chlorinated dioxin contamination of
chickens and eggs the Texas Department of Health has requested "that FDA
provide guidance as to health or regulatory significance as well as action
guidance" (W. Remle Grove, see attachment # 1). In response to this
request, as submitted through DRG, we have reviewed the available
information on the toxicity of several dioxin congeners. Based on this
review we are suggesting the following levels of concern (LOG) for these
substances in chicken and eggs.
Levels of Concern^/
HCDD
HpCDD
OCDD

300 parts per trillion
500 parts per trillion
3 parts per million

a/ Because the amounts of chicken and eggs consumed are similar, a
uniform level of concern for the respective contaminants can be applied to
each food item.
The rationale, biological and/or toxicological end-points and factors
utilized in the development of the above LX are identified in subsequent
pages and attachments. It is important to recognize that the available
literature from which these levels were derived is limited.
We emphasize that these levels apply only to the present situation in Texas
.and do not have general applicability to contamination by the dioxin
congeners HCDD, HpCDD and OCDD in food. In this situation the various
isomers of each congener will not be dealt with individually but rather as
a group (e.g., as congeners). This is so because of a lack of- a)
biological and/or toxicological studies on specific isomers, and b)
knowledge of the presence of individual isomers involved in the Texas
situation. It should also be noted that while the carcinogenicity of these
congeners was assssed, where specific studies were available, the potential
exposure to them in the Texas incident is considered to be of a relatively

�-2-

short duration (e.g.,-possibly several weeks up to several months).
Therefore, carcinogenic potential was not used as the toxicological
determinant in deriving the LXs for dioxins in chicken and eggs. It is
equally important to recognize that other toxic manifestations, such as
reproductive and/or teratogenic effects, may result from pulse (single) or
short-term (days to weeks) exposures to dioxins such as the HCDD congener.
It is the concern for these non-carcinogenic effects which serves as the
basis for our evaluation, again since lifetime exposure is not an issue.
Since the tetrachlorodibenzo-p-dioxin (TCDD) congener is the best studied
and most toxic member of this class of toxicants, the health assessment
performed on tha presence of TCDD in freshwater fish from various areas of
the Great Lakes (F. Cordle, Reg. Tox. Pharm., 1;379-387, 1981; see
attachment # 2) will be used as the basis for the establishment of LXs for
HCDD, HpCDD and OCDD. In that assessment it was determined from a
multi-generation reproduction study in rats that the no-effect level for
TCDD was 1 nanogram (ng)/kg b.w./day. In keeping with these findings, a
concern level of 25 ppt TCDD in fish was recommended by FDA to State
officials. The value of 25 ppt TCDD and a fish consumption value of 37
g/day (99th percentile) is used in the present assessment to derive maximum
daily intakes for the other dioxins (HCDD, HpCDD and OCDD) based on
appropriate safety factors and their biological and/or' toxicological
potency in relation to TCDD.
In order to evaluate the relative biological/toxicological potency of these
toxicants, several different types of studies were assessed. A number of
studies have shown that there is a distinct relationship between the
ability of the dioxins to elicit several of their toxic and/or biological
manifestations and to bind to a cytosolic-receptor. These studies have
shown that for the dioxins to produce any appreciable degree of
toxicological and/or biological activity the four lateral ring positions
must be occupied by chlorine atoms and at least one ring position must be
unsubstituted.
The comparative induction of aryl hydrocarbon hydroxylase (AHH) by a number
of dioxins, including TCDD, HCDD, HpCDD and XDD has been studied in rat
hepatoma cell cultures by J. Bradlaw and co-workers (Fd. Cosmet. Tox.,
.18:627-635, 1980). Their studies showed that the relative potency of the
most active congeners of HCDD, HpCDD and XDD were 1/10, 1/200 and 1/25,000
of that of TCDD (relative potency of 1), respectively. In similar studies
performed ty A. Poland and associates (Mole. Pharm., 2-736-747, 1973) on
AHH induction in chicken embryonic livers, the relative biological potency
Of HCDD was determined to be approximately 1/4.5 when the potency of TCDD
was 1, while OCDD was shown to be inactive.
Another type of study which was used to evaluate relative toxicological
potency was acute oral toxicity. The following table is a compilation of
acute oral LD5QS in the guinea-pig for those congeners that have been
studied (from 3. Huff and co-workers, Enviro. Heal. Perspec.. 36:221-240,
1980).

�-3-

Single Oral LD$Q
(ug/kg b.w.)
Congener
2,3,7,8-TCDO
1,2,3,4,7,8-HCDD
1,2,3,6,7,8-HCDD
1,2,3,7,8,9-HCDD
1,2,3,4,6,7,8-HpCDD

Guinea-pig
2
73
70-100
60-100
&gt; 600

Acute oral toxicity of dioxin congeners has been studied in other species,
however, the guinea-pig is being used in this analysis because on an acute
basis it is the most sensitive species. An examination of these values
reveals that the acute oral LDjns for the three HCDD isomers are very
similar. To compare the acute toxicity of HCDD to that of TCDD the lowest
reported value of 60 ug/kg b.w. will be used. As in the previous
derivation of relative potency, if TCDD is given a value of 1, it follows
that the relative potency of HCDD is 1/30 (60 ug/kg-HCDD/2 ug/kg-TCDD) of
that of TCDD. Relative potencies for HpCDD and OCDD could not be
calculated, because the acute LD$Q for HpCDD was not specifically
identified ( &gt; 600 ug/kg b.w.) and no value for OCDD has been reported.
A number of reproductive/teratogenic studies have been performed with TCDD,
HCDD and OCDD, while none have been reported for HpCDD. In these studies
the lowest no observed effect level (NOEL) for TCDD was shown to be at a
dosage of 0.001 ug TCDD/kg b.w./day (3-year rat reproduction study; F.
Murray and co-workers, Tox. Appl. Pharm., 50:241-252, 1979). In a
teratology study by B. Schwetz et al. (Enviro. Health Perspec.. 5_: 87-99,
1973) the lowest dosage shown not to effect embryonal or fetal development
for HCDD was 0.1 ug/kg b.w./day. In this same study OCDD did produce
embryotoxicity (subcutaneous edema), but no teratogenic effects at 500
mg/kg b.w./day, however, the next lowest dosage, 100 mg/kg b.w./day, did
not cause either teratogenic or embryotoxic effects. In comparing the
NOELs for these dioxins a relative potency of 1 is assigned to TCDD. It
follows that the relative potency of HCDD is 1/100 and that of OCDD is 1/1
X 108 in terms of reproductive toxicity/teratogenicity.
Only one of the congeners of interest, namely HCDD, has been studied in a
long-term carcinogenic bioassay (NCI, Technical Report Series No. 198, NTP
No. 80-12, 1980). In this study a mixture of two isomers, 1,2,3,6,7,8- and
1,2,3,7,8,9-HCDD, was shown to exhibit a lowest effect level (uEL) for
neoplasia in B6C3F1 mice of 0.2 ug/kg b.w./day. This compares to the LEL
of 0.01 ug/kg b.w./day which was observed by Kociba and co-workers (Tox.
Appl. PhaTm., _46:279-303, 1978), in a two-year chronic study in rats. The
relative ootency for neoplasia of HCDD in comparison to TCDD would,

�-4-

therefore, be 1/20. It must be emphasized that in this instance the toxic
end-point of neoplasia was used solely to derive a relative potency factor
for HCDD, not to address the issue of carcinogenicity, per se.
The following table contains a summary of the relative potencies determined
for HCDD, HpCDD and OCDD by the methods discussed above.
Relative Biological/Toxicological Potencies*
Dioxin
Conqenar

AHH Induction
Chicken Liver
Rat
Embryo
Hepatomas

1

1

1/4.5

1/10

HpCDD

NR

1/200

OCDD

NA

1/25,000

Acute
Oral
LDsn

TCDD
HCDD

'

Reproductive/
Teratogenic
Carcinogenic
Bioassay
Studies

1

1

1

1/100

1/20

NR

NR

NR

NR

1/1 X 108

NR

1/30

* - 1 is the highest level of activity.
NR - not reported; studies have not been performed.
NA - not active
It is apparent that of the three congeners of interest HCDD demonstrates
the greatest activity with HpCDD and OCDD following in order of magnitude.
This follows the structure activity relationship for this class of
compounds which indicates that those congeners with chlorines in positions
2,3,7 and 8 and with at least one unoccupied ring position will demonstrate
the greatest biological/toxicological activity.
Derivation of LQCs
HCDD
The relative potencies of HCDO derived from the various studies cited above
range between 1/4.5 and 1/100. Since the incident in question involves an
acute or short-term exposure the risk of a pulse (single) exposure during
pregnancy would be of most concern. Therefore, while not ignoring the
trend suggested by the smaller relative potency factors for HCOD, more
weight is given to the larger factor determined on the basis of the
teratogenic study performed with HCDD. It was, therefore, decided that a
more appropriate relative potency for HCDD is 50. This was then used to
derive the LOG for HCDD according to the following calculation -

�25 ppt* X 50 X (36.8 g/53.9 g)** = 853 ppt (rounded to 850 ppt)
*-• The 25 ppt used in this calculation is the health advisory level which
was issued for the TCDD contamination of fish from the Great Lakes. As
it was stated previously it is the Great Lakes health advisory which is
used as the basis for the derivation of the levels of concern for the
higher chlorinated dioxins in the present assessment.
**- ratio of food factors; 36.8 g/day - 99th percentile intake for fish;
53.9 g/day - total intake for eggs (28.5 g) and chicken (25.4 g)
consumed by children 2 to 5 years of age (supplied by Dr. F. Cordle,
HFF-108, 4/14/83, see attachment #3).
This level of' 850 ppt, however, applies to the adult and not to children.
The latter are of greater concern in this case because they are likely to
consume more eggs and chicken per kg of body weight than adult. Therefore,
the 850 ppt level is divided by a factor of 3 to account for this increased
exposure of children to give a value of 283 ppt which is rounded off to
give a LOG of 300 ppt for HCDD.
HpCDD
The amount of data available on HpCDD is quite meager. If the relative
potency value of 1/200 is used, a LOG is derived which is unduly high,
particularly in light of the information on the structure-activity
relationship of the dioxins. The two hepta isomers have chlorine atoms at
carbon positions 2,3,7, and 8, one unoccupied carbon position, and only
differ from the most toxic hexa-isomers by the presence of one additional
chlorine atom. Therefore, it is felt that a LOG of 500 ppt would be more
appropriate.

XDD
After evaluating the available information on the toxicological and/or
biological potency of XDO it was determined that the most reliable data
was that from the reproductive/teratology study reported by Schwetz e_t al.
(1973). In that study the NOEL for OCDD was 100 mg/kg b.w./day Using this
value together with a 1000 fold safety factor and accounting for the lower
body weight of 2 to 5 year old child, a tentative LOG of concern equivalent
to 30 ppm was determined, as shown below:
' LOG =
a
«
a

100 mg/kg b.w./day (NOEL) $ 1000 (S.F.)
0.1 mg/kg b.w./day x 16 kg b.w. (child)
1.6 mg/day f 53.9 g/day (total consumption of
chicken and eggs by child)
29.68 ppm or 30 ppm

Wh:!le the value is based on "in vivo" experimentation, it appears to be
unrealistically high for a congener which belongs to a class of toxicants,
e.g., dioxins, for which so much concern has been expressed. Furthermore,
it should be stressed that this value is derived from a single study using

�-6-

only one animal species, e.g., the rat. If we consider the-"in vitro" data
on AHH enzyme induction, it is seen that OCDD has only a minute fraction of
the activity reported for TCDD. Nevertheless, there is some concern over
the possibility that exposure to OCDD at the level suggested by the
tentative LOG of 30 pprn may result in some degree of enzyme induction
activity in humans. Therefore, the application of a further safety factor
of at least 10 is considered appropriate. Thus, a LOG of 3 ppm is
recommended for OCDD in chicken and eggs.
Since the amounts of chicken and eggs consumed are similar, a uniform LOG
for the respective congeners can be applied to each food item. Again it
must be emphasized that these levels apply only to the present situation in
Texas and have rio application to other incidents. It should also be
reiterated that while the induction of neoplasia was used to derive one of
the comparative relative potency factors for HCDD the issue of
carcinogenicity was not utilized directly in this evaluation because of the
limited, short-term exposure of this situation. Finally, although
structure-activity information was considered in deriving the LQCs for the
higher chlorinated dioxins it is recognized that additional data on such
relationships is required to refine the significance of such parameters in
the toxicoldgical assessments of these toxicants.

ichael Bolgef, Ph.D.
Garfield N. Biddle, Ph.D.
Attachments
cc:
HFF-100

HFF-150 (Blumenthal)
HFF-152 (Jackson/Edwards)
HFF-159 (Shibko)
HFF-159:GNBiddle:MBolger:clw:4/29/83:472-5706:2095A

�15. 83--261-360

m PROCESS

12 SUBS - SCRAPINGS

FROM EQUIPMENT
lb. 33-292-061
1 SUB - SHEEP WOOL FROM SHEEP
HEAL SCREEN
RECEIVED FROM H.T.C. RENDERING,
SAN ANGELO, TEXAS
j?. 83-261-062
1 SUB - «EAJ S BONE HEAL
SHEEP HEAL
18, 83-292-063
1 SJ!J - POULTRY MEAL

!•&gt;. S3- 292- 064
1 SUB - POULTRY HEAL
20. 83-232-065
1 SUB - MEAT 1 BONE MEAL
*Ji. 33-292-066
1 SUB - POULTRY HEAL
i2. 82-292-067
1 SUB - HEA1 1 BONE HEAL
L'li. 83-292-068
J SUB - MEAT I BONE HEAL
:'. 33-2^2-069
;.
1 SUB - UlftTf DEBRI5» ffcOH
IKS7PE HEARTH OF OLD
1NCENERATOR

•:.Mirriii 10 ciNCiMMAii LABORATORY:
23 SUBS - LUBRICANTS, DEORORANTS,
INSECTICIDES. BOILER
COMPOUNDS, VARIOUS
LIQUIDS ANO POUtERS.
UPON RECEIPT OF C/R'S, I WILL DESCRIBE SUBS THAT RELATE TO EACH SAMPLE.
i.M RICAKDS TO 83-261-350, SUB 41 HEAT t bONE MEAL* SUB 42 ANIHAL FAT,
COLLECTED 5ROH LOAPS RECEIVED FROM TEXAS 6Y PRODUCTS COMPANY, SAN ANTONlD. IT
miEVElr TKAt B0TK COMPANIES #RF UNUER THE SftKE 0«NE«T, 1K1S: «2tt &amp;
4/11/83. AS TO COMMON SUPPLIERS, PROCESSING, ETC.

�&lt;'«JTL THAI 83-261-350. COLLECTED ON 4/4/83 WAS RECEIVED FROM TEXAS BY-PRODUCTS
mnt-ANY, SAN ANTONIO, TEXAS. SUB *1 HF.AT 1 BONE HEAL WAS COLLECTED FROM THE
TRANSPORT TRUCK, AND ANALYSIS REVEALED 25.!&gt; PPK. OUR SAMPLE 83-260-356. MEAT
i BONE MEAL. COLLECTED 0« 3/H/B3 REVEALED 16.0 ?pH TCP'S. THIS SAMPLE WAS
COLLECTED FROM A STORAGE BIN, AND IS NOW BELIEVED TO BE A PORTION RECEIVE*
n»DH TEXAS BIT-PRODUCTS.
TEXAS WNUER1N6 IS OWNED BY HUBEW L. L1NENBERQER, AND ALSO FUNCTIONS AS THE
PRESIDENT. LINENBER6ER ALSO OWNS 75* OF THE STOCK OF TEXAS BY-PRODUCTS, SAN
'.rtlOMlO, AS WELL AS OWNING A hAJOR INTEREST 1M TEX -HENS, INC., MIXON, TEXAS.
TE/.AS kENliERlNG RECEIVED APPROX. 3-4 LOADS OF HEAT I BONE iiEAL PEft WEEK FROM
TrxAS BY-PRODUCTS, ESTIMATED AT APPROX. 150,000 LBS. OK MORE. IT WAS REPORTED
THnT THIS HEAT 1 BONE HEAL IS VERY HIGH IN FAt CONTENT AND IS RUN THROUGH THE
EQUIPMENT AT TEXAS RENDERING TO EXTRACT ADDITIONAL FAT, IT IS ALSO REPORTED
THAT PRODUCT SAMPLED UNDER 03-261-350, SUB 12, ANIMAL FAT FROM TEXAS
ST-PRODUC7S IS ACTUALLY STREET GREASE. Ml IS NOT ANIMAL FAT PROCESSED BY
ANTONIO. REPORTEDLY DOES TO JACOB-SIERNS, HOUSTON, TEXAS.
WHILE TEXAS PJNDER2WJ RECEI'/ES KEAT I PONE HEAL AND STREET GREASE- FROK TEXAS
BY-PRODUCTS, SAN ANTONIO, TEXAS RENDERIMf, JOES NOT SHIJ1 PRODUCTS TO THEM.
ALSO IT WAS REPORTED, THESE FIRMS DO NOT HAVE COMMON SUPPLIERS. ALSO NO
PRODUCTS ARE SHIPPED PROM TEXAS RENDERING TO TEX-HENS, INC., NIXON, TEXAS.
(. GENERAL PROCESSING FLOW AT TEXAS RENDERING IS AS FOLLOWS:
AS PRODUCT IS RECEIVED, HEAT X BONE MEAL, DEAD ANIMALS, SCRAPS, ETC., IT IS
^JftPED JKTO A P3T WHERE 37 IS AUGCRED TO 70 AH 3NI&gt;US?kiAL 6K3MER, AUGERS OVER
rAGMETIC PLATE (REMOVE HE? AD TO MEAT STORAGE VAT, 10 QHE OF 5 HEAT COOKERS.
THE COOKERS ARE CHARGED WITH APPROX. 6,000 L*S. OF PRODUCT AND APPKOX. 2,000
LK-. OF ANIMAL FAT- JS ADBE&amp; (USUALLY PROCESSED THE rtiGHT BE?OR£&gt;. AFTER
COOKING AT APPROX, 313 DEGREES t. THE PRODUCT EXITS AND SCREENED WITH THE FAT
V.CIM13 TO ONE OF 3/20,000 LB. WORKING VATS. THE FAT IN THESE VAIS IS USED TO
INTO THE COOKING VATS AS STATED ABOVE.
IS NKXBCD FROM THESE WORKING VATS. IT MAINS TO A FLAT DRYING VAT TO

»&gt;r off WATER. FROM HERE, XT. is PUMPED TO EITHER OF 3/30,000 LF\ STORAGE VATS.
^r. THE MEAT EXITS THE COOKER, IT GOES TO THE PRESSES «HESE BORE FAT IS
UTKACTED (PAT GOES TO THE WORKING VATS). THE MEAT THEN PASSES THE SCfcEENEJc,
.MJBCIXI kA»a« ftiaeso A* »««4S, MAIM, »*o.t &gt;H».» M«MOV»». *M» HBis* *t*0*4 ««aa *o

T'riE HAMMER t»U. THEM THE MEAt T&amp; EITHER OF 8/60,000 t&amp;3. STORAGE BINS AS
iTMISHED MEAL. THE BONES, ETC., REMOVED BY THE SCREENER, GOES BACK TO THE
L'KJSINAL AUGER AT THE STARTING POINT OF THE PROCESS.
L'JSCUSSIONS WERE HELD OK MONDAY. 4/U/83, BY HOUSTON STATION WITH OFFICIALS Of
TrlC TEXAS KEPT. OF AGRICULTURE AND TEXAS DEPT. OF HEALTH AND OUR SAMPLE
ilTSULIS KNOWN AT THE PRESENT TIME WERE PISUCSSED. THE INTRASTATE SHELL EG^S
«t*£ DISCUSSED WITH TEXAS DEPT. OF HEALTH, HOWEVER, THEY DO MOT HAVE THE

:«*AmniES OF ANALYSING FOR POP'S 10- DETESHINEiTHS CU»*EM STAJUS- or EGGSC t
A

"P:0n SMITH FARMS AMD POSSIBLY OTHERS. !PJ^
**&lt;WHifc- CU5RENT ASSAYS. THEY
\Ki «ILL1HG TO ACT., HOWEVER ^REQUESTED THAT FDA PRO'/lIiE GUIDANCE AS TO HEALTH
'•¥" REGULATORY SICNifANCE AS WELL AS ACTION GUIDANCE.

�nr xcxft* DEFT. OF AGRICULTURE IS QUITE CONCERNED AND 15 CURRENTLY
lVG SAMPLES SUBMITTED BY 1KB F1RH OF FINISHED PROBUCT, HO«BVBR&gt; THEY
•ilSO R£QU£S7£H
TKun THE HIGH LEVELS Of ?C?'&amp; FOU*fB IW «EAI I BOME HEAL FUtOM TEXAS
Pr-PRQPUClS, SAN ANTOfilO, IT A?f-EARS THAT THIS COULD BE A CONTINUOUS SOURCE OF
LOfJTAMiNATEB PRODUCTS. AN INVESTIGATION OF THIS FIKH IS CURRENTLY BEING.
UISUUSSED.

�/'*•
REGULATORY TOXICOLOGY AND PHARMACOLOGY 1, 379-387 (1981)

The Use of Epidemiology in the Regulation of Dioxins
in the Food Supply1

FRANK CORDLE
Epidemiology and Clinical Toxicology, Bureau of Foods, food and Drug Administration,
Washington, D. C. 20204

Received November 1981

Residues of teirachlorodibenzo-p-dioxins (TCDD) were detected recently in several species
of freshwater fish from various areas of the Great Lakes. Concern for the potential human
health risk associated with the consumption of these fish prompted the Food and Drug Administration to assess epidemiological and toxicologies! TCDD data in order to determine the
need for regulatory action. In the assessment, pertinent animal and human data and daia for
the TCDD residues in the freshwater fish, for the amounts of the different fish species consumed
and for the number of individuals who consumed the fish, were evaluated. The various methods
of evaluation used to reach a regulatory decision are described.
*

INTRODUCTION
Although epidemiology may have first been used by Hippocrates, the definition
or meaning has undergone some significant changes since then. First described as
the study of epidemics and, later, as the study of the determinants of differences
in disease distributions in human populations, epidemiology today, especially in
regulatory agencies, refers essentially to the activities of the epidemiologist. In a
regulatory agency such as the Food and Drug Administration (FDA) the role of
the epidemiologist is to assimilate, digest, and synthesize the best available data
from survey, clinical, and laboratory experiences, either firsthand or from the scientific literature: these human and animal data are then combined and interpreted
in order to address a basic question: Does the evidence of adverse human health
effects from exposure to the various chemical substances that fall under FDA
regulatory authority present a risk to public health safety that is sufficient for FDA
to initiate or make a change in regulatory action? The importance of the contri• Presented at the international symposium Human Health Aspects io Accidental Chemical Exposure
of Dicxir.s—S::aisgy for Environmental Reclamation snc Corr.mur.itv Protection, organized by the
International Academy of Environmental Safety (1AES) and the International Society of Ecotoxicolojy
and Er.viro.-.rncnta! Safety (SECOTOX) joiniiy with the Institute Superiore di Sanita. Rome, and the
Geseilschafrfur Strahien- und Umweh Forshung MbH, Munich.

379

o::?-::-oo;si/o:&gt;o379-o9so:.oo/o
Cc??Ti9i: 5 19M tv Academic Presi. Int
.Mi nf hu of rep.'odumor. in &gt;nv form reserved

�380

FRANK CORDLE

bution of epidemiology in the regulatory public health arena seems obvious. Without
adequate assessment of factors that appear"to increase the risk of disease in humans
from chemical substances in the food supply, food may be destroyed, the public
may be unnecessarily inconvenienced or inadequately protected, and the costs may
be enormous. In short, epidemiological efforts are directed toward the prediction
of such risk at the community, state, or national level.
It is quite likely that the majority of humans are exposed to a large number of
chemical substances in small amounts over an extended period of time rather than
to large doses such as those described in the mercury episode in Minamata or in
the PCB exposure in Japan. The importance of the possible cumulative effects from
these small doses versus the importance of the effects from a single large dose or
.from relatively large doses over a short period of time is the subject of considerable
scientific debate.
Much of the information concerning the toxicity of various chemical substances
has been obtained from experiments in animals. In general, safety testing depends
upon the fact that as the exposure dose is decreased, toxic effects also decrease,
and a dose is finally established at which "no observed effects" are seen. Such
dose-response relations are central to toxicity studies in animals and should be ef
equal concern in the evaluation of human exposure to a variety of environmental
and other insults. However, dose-response relations in humans must be established
or identified with a great deal of care and caution. Outcome may vary greatly in
significance: At one extreme is death and at the other are changes in physiological
or psychological function. The weight that should be given to each relation in
formulating regulatory policy may vary greatly.
The lack of good examples of dose-response 'relation, even in the area of occupational exposure, is remarkable. Where dramatic incidents of exposure to environmental contamination have occurred through ingestion of contaminated food,
efforts to establish an acceptable dose-response relation in humans have met with
little success.
However, epidemiologies! study should not be limited to outbreaks of disease
that are obviously caused by high exposures to toxic chemicals: it should be squally
concerned with the effects of lower, more prolonged, and sometimes insidious exposures.
EPIDEMIOLOGICAL METHODS
In the traditional manner, epidemiologists deal wi;h epidemics by interpreting
patterns of disease, testing hypotheses, and assessing the risks and benefits of various
options. Their methods involve the use of two categories of epidemiology often
referred to. as analytical and descriptive epidemiology. The analytical epidemiclogical methods generally involve either a case-control, retrospective approach or
a cohort, prospective approach.
In analytical epidemiology, the goal of epicsmioiogica! activity is to identify and.
if possible, to quantify the association between a cuusii exposure or characteristic
and a disease under circumstances that permit the best possible discrimination
between cause and aiternative hypotheses. Chance will always affect the alternatives: thus the feasibility of such a study is limited by factors such as sample size.

�EPIDEMIOLOGY AND REGULATION'OF D1OXINS

-"

381

Since a precise hypothesis permits the use of a well-thought-out and properly
planned study design, it is better to use the cohort approach to measure relative
and attributable risk, for example, than to try to detect trends from descriptive
data. Nevertheless, sample size considerations, cost, and time constraints often
restrict the kind of epidemiological study undertaken, even though the cohort approach might be preferred for a given problem.
Case-control studies of disease, i.e., studies looking at the past history of exposure,
are often more feasible than cohort studies because they can be conducted in a
relatively short time and are easily repeatable, and because a large number of cases
can be studied economically. They do have some special liabilities, however, in
terms of validity, since such studies depend entirely on the comparability of cases
and controls and on the specific methods used to measure the exposure. Although
frequently used, the methods for estimating relative risk or risk ratio from casecontrol studies also present some special problems of inference.
Cohort studies, i.e..-studies looking forward in time, are especially costly because
of the time involved in the prospective follow-up. They do, however, provide an
opportunity to compute a more reasonable relati%re and attributable risk, and specious relationships resulting from bias in data collection are less likely to occur.
Descriptive epidemioiogical methods can be used by a regulatory agency such
as FDA to determine trends in disease and magnitudes of exposed populations
largely from data that are readily available, e.g., mortality dau. data from National
Cancer Institute (NCI) surveys, census data, and food consumption data. The goal
of these studies is io identify any unexpected changes in incidents or.mortality
through surveillance of the available data for time trends and through probes of
specific data collected during research activities or gathered in support of regulatory
decisions.
Epidemiological studies also provide information that is used to identify and
quantify differences in species responsiveness to environmental agents in a variety
of other ways. One use. for example, pertains to the difficulty associated with
cornparir.c data derived from studies of highly inbred animal strains to data of a
genetically heterogeneous human population. In this case, epidemiological methodologies provide the means for stratification of study data according to sex, age,
race, and other variables that characterize human populations. Certain problems
rr.ay also be minimized when epiderniological considerations are employed in risk
assessments that are based on comparisons involving data of humans and data of
animal models. These include problems associated with limited sample sizes, znigra'.ior. in and out of the exposure area, and toxicity due to causes other than that
as-sociated Vjth exposure to the etioiogic agent under study.
EPIDEMIOLOGICAL AND TOXICOLOGICAL ASSESSMENT
OF TCDD EXPOSURE
Recent concern for the potential human health risk associated with exposure to
residues of the tetrachiorocibenzo-p-dioxins (TCDD) in several species of freshwater fish from various areas of the Greai Lakes has resulted in an epidemioiogical
arc toxicological assessment of the problem that utilizes currently available data
from a variety of data sets. For a regulatory decision to be made, several elements

�3S2

FRANK CORDLE

were needed. These included data for the TCDD residues in the freshwater fish,
for the amounts of the various fish species consumed and for the number of individuals who consumed the fish, and assessments of pertinent animal data and previous human exposure to TCDD.
Animal Data
A number of lexicological studies with TCDD have been conducted to assess
the potential for acute toxicity and teratogenesis. Kociba et al. (1976) reported the
results of a subchronic study using rats that were given 1.0, 0.1, 0.01, 0.001, or
0 /jg TCDD/kg body wt/day for 5 days/week for 13 weeks. Doses of 1.0 Mg TCDD/
kg/day caused some mortality, inactivity, decreased body weights and food consumption, pathornorphologic changes in the liver, lymphoid depletion of the thymus,
increased urinary excretion of porphyrins, and minimal alterations of some hematopoietic components. Doses of 0.1 ^g TCDD/kg/day caused decreased body
weights and food consumption and slight degrees of liver degeneration and lymphoid
depletion. These data indicate that no discernible ill effects occurred in rats given
0.01 or 0.001 jig TCDD/kg/day for 5 days/week for 13 weeks.
In a 2-year chronic study in rats Kociba et al. (1978) reported that the ingestion
of 0.1 ,ug TCDD/kg/day caused an increased incidence of hepatocellular carcinomas and squamous cell carcinomas of the lung, hard palate/nasal turbinates, or
tongue, whereas a reduced incidence of tumors of the pituitary, uterus, mammary
glands, pancreas, and adrenal glands was noted. Other indications of toxicity at
this dose level included increased mortality, decreased weight gain, slight depression
of erythroid parameters, and increased urinary excretion of porphyrins. Gross and
histopathologic charges were noted in the hepatic lymphoid. respiratory, and vascular '.issues. The primary hepatic ultrastructural change at this high dose level
was proliferation of the rough endopiasmic reticulum. Terminal liver and fat samples from rats given this high dose level contained 24.000 and S100 parts per trillion
(ppt) TCDD, respectively. Rats giver. 0.01 ng TCDD/kg/day for 2 years showed
less severe toxicological effects than those given the highest dose level. These included liver lesions (including hepstocellular nodules) and lung lesions (including
focal alveolar hyperplasia). Terminal liver and fat samples from rats given this
dose level contained 5100 and 1700 ppt TCDD, respectively. Ingestion of 0.001
yg TCDD/kg/day (22 ppt in the die;) caused no effects of any toxicological significance. Terminal liver and fat samples from rats given this low dose level each
confined 5-^0 ppt TCDD.
]- a 3-year reproduction study in rais given doss levels of 0. O.OOL 0.01, or 0.1
ug TCDD/'kg/day, Murray ei al. 'J979) reported no significant toxic effects in
the/c-ceneration rats of cither se.x curing the 90 days of TCDD ingestion prior to
': mating. However; significant decreases in fertility and neonatal survival were observed in the/o-generation rats receiving 0.1 ps TCDD/kg/day. At 0.01 Mg TCDD/
kg/day, fertility was significantly decreased in the/i and/ : generations, but not
in the/; generation, and decre55.es in litter size at birth, gestations! survival, and
neonatal survival and growth were also noted. Among the rats receiving 0.001 ^g
TCDD/kg/day, no effect on fertility. !i;:er &lt;ize at birth, or postnatal body weight
was observed in any generation. No consistent effect on neonatal survival was
observed at a dose level of 0.001 pg TCDD/kg/day. •

�EPIDEMIOLOGY AND REGULATION OF DIOXINS

383

Allen et al. (1977) reported results of a subchronic study in which female rhesus
monkeys consumed a diet containing 500 ppt TCDD for periods as long as 9 months.
It was calculated that these monkeys ingested a total of 2-3 Mg TCDD/kg body
wt over the course of the 9-month study. Clinically, these monkeys showed changes
similar to those described by McConnell et al. (1978) as well as some hematoiogic
depression and hemorrhages in various tissues. Hypertrophy, hyperplasia, and/or
metaplasia were noted in the epithelium of the bile ducts, salivary glands, bronchi,
pancreatic ducts, sebaceous glands, skin, gastric linings, and urinary tracts of these
monkeys given diets containing 500 ppt TCDD.
Human Experience
Alihough 22 incidents of human exposure to TCDD in connection with the
manufacture of chlorinated phenols have been reported worldwide since 1949
(Holmstedt, 1980). there remains a scarcity of reliable information concerning the
results of these exposures.
In a recent report of the mortality experience of a cohort of workers exposed to
TCDD in Nitro, West Virginia, in 1949. Zack and Suskind (1980) described some
of the signs and symptoms observed in the exposed population shortly, after the
accident occurred. Employees who-worked in the area of 2,4.5-trichlorophinol
(TCP) production or were involved in the cleanup began to develop symptoms
immediately following exposure to the material, which was discharged froir. the
autoclave. Symptoms included eye and respiratory tract irritation, headache, dizziness and nausea, and a severe irritant reaction of the exposed skin. After these
initial symptoms subsided, chioracne and other symptoms became evident. A total
of 12 more severely affected workers were examined or. three occasions during the
period 1949-1953. Another 26 persons with chioracne :hat was apparently unrelated to the accident were also examined in 1953.
The ciinical symptoms included acneform lesions: severe pains in muscles of
upper and lower extremities, shoulders, and thorax on exertion: fatigue: nervousness
and irritability: decrease in libido: dyspnea: vertigo: and intolerance to cole. All
of the cases showed evidence of chioracne. For the six workers examined curing
1949 and 1950. another examination was carried out in 1953. and at that time six
additional workers involved in the accident were also examined! The findings in
ihis later examination indicated a general regression of both the cutaneous and
ne.-cuiijriccus symptoms w h i c h had been present earlier. No specific leveis o; exposure could be determined.
In other reports of industrial exposure 10 TCDD frc.T. Great Britain, the Netherlands. \\fisi Germany, and Czechoslovakia, chioracne was the most common and
prominent sign observed following exposure. In some -sports liver function tests
indicated liver damage, whereas in other reports they die not. Two major problems
er.cour,:e:tc in all of these studies were the lack of 2. tltitr identification of •.hose
e.v-&lt;&gt;=d. other than their subsequent development of chioracne. and the absence
of any measures for the levels of exposure ihar might have taken place.
Pszdsrova-Vejlupkova et a!. ( 1 9 8 1 ) reported results of a 10-year follow-up study
of workers exposed ;o TCDD between 1965 snd 196s curing the production of
2.4.5-trichloropheno.xyacetic acid (2/,5-T). In this s t u d y group of 55 individuals

�384

FRANK CORDLE

(originally 80 of the 400 persons engaged in., the production became ill), the first
indications of illness were feelings of sickness, fatigue, weakness in the lower extremities, and the formation of chloracne. Subsequent examinations indicated that
about 20% had mild hepatic lesions.
During the 10-year follow-up study of these exposed individuals, most of the
patients did not experience all of the symptoms and signs of intoxication, and some
patients showed the same symptoms and signs as others, but in different combinations. It is assumed that in this type of intoxication all the systems and organs
mentioned in the study were simultaneously affected, although some were affected
only slightly. This assumption is supported by several facts. Fluorescence of liver
tissues in ultraviolet light, which is a sign of pathological porphyrin metabolism,
was present in all cases of necropsy and biopsy, i.e., in persons for whom long-term
monitoring of porphyrin excretion in urine was carried out and in whom 5-aminolevulinic acid values were constantly within normal limits'. Probably a slight
subclinical lesion was present in each of these patients. Further evidence was furnished in repeated neurological examinations. Polyneuropathy of the lower extremities was manifest in some patients only in the third or fourth year of illness. There
is definite clinical and electromyographic evidence that the results of the first examinations conducted when the illness commenced showed that the patients were
entirely normal.
Additional study results have been reported recently by Zack and Suskind 0980),
Ott et al. (1980), and Cook et al. (1980), describing ;hs mortality of employees
engaged in the manufacture of 2.4.5,-T. In two of these studies cohorts of employees
were assembled on the basis of their exposure to T.CDD. which was indicated,by
the presence of chloracne; the ihird cohort consisted of individuals employed over
the same time period. Unfortunately, each of these three cohorts comprised a
limited number of individuals: e.g., the chloracne groups contained 121 and 49
individuals and the employee group contained 204.
In each of these studies there does not appear to be an apparent excess in total
mortality rate or in deaths from malignant neoplasms. It must be pointed out,
however, that each of these studies does have limitations both in the size of the
population studied and in other methodological areas, such as exposure levels.
For a more detailed description of these studies as well as the Seveso incident,
the reader is referred to the original papers and to Hoimstect (1980), Reggiani
(19SO), and Pocchiari et al. (1979).
Hitman Exposure to TCDD Residues in Fish
Although there are no epidemiological studies which have firmly established an
association between cancer in humans and TCDD exposure, 2nd although comparisons of human exposure data and animal studies appear to indicate that humans
may be less sensitive than animals to TCDD exposure, prudence dictates that
human exposure to TCDD be kept to 3 minimum. With :h:s public health objective
ir. m;rd. FDA recently compieted an assessment of the problem of TCDD residues
in some species of freshwater fish in the Great Lakes for ;he purpose of determining
whether consumption of such fish provided a potential public health problem.
Results of the analyses of fish samples collected by Canada and the United States

�EPIDEMIOLOGY AND REGULATION OF D10XINS

-

385

TABLE i
HUMAN CONSUMPTION OF DIOXIN BASED ON FISH CONSUMPTION DATA
Total daily intake (ng*)

Total daily intake/body wt (pg'/kg)

From all selected
species

From all selected
species

Hypothetical
dioxin residue level
in fish consumed
(ppf)

90th
percentile

99th
percentile

From
pike, 99th
percentile

90th
percentile

99th
percentile

From
pike, 99th
percentile

100
SO
25

1.57
0.77
0.38

3.683
1.84
0.92

8.4
4.2
2.1

22
11
5.5

50
26
13

120
60
30

' ppt • pans per trillion.
" 1 microgram (»g) "..1000 nanograms (ng).
' 1 ng - 1000 picograms (pg).

indicated that TCDD levels as high as 30 ppt with an average value of 25 ppt were
present in the edible portion of salmonoid fish (salmon, trout) from. Lake Ontario.
Lower levels of TCDD were reported to be present in the edible portions of commercial species (bullhead, perch, catfish, sucker, etc.) from Lake Ontario^ although
up to 40 ppt TCDD were found in'eel and smelt from the lake. Less than 10 ppt
TCDD was seen in samples from Lake Erie, and limited data for_fish from the
other Great Lakes were similar to those obtained from Lake Erie fish, except that
higher levels of TCDD were present .in fish from Sagir.aw Bay, Michigan.
Data on fish consumption from the National Marine Fisheries Service (NMFS)
were extracted for the eight Great Lakes states, Illinois. Indiana. Michigan, Minnesota. New York, Ohio, Pennsylvania, and Wisconsin. These data were collected
in a national sample of households, consisting of approximately 25,000 individuals.
From the data presented, individuals who consumed the species of interest, i.e., the
species currently being analyzed for dioxin residues were identified in the total
sample, and the mean fish consumption, in grams per cay. was computed. The 90th
and 99th percentiles were also computed. On the basis of the proportion of individuals in the sample population consuming the species of interest, 17,057,791
individuals in the eight Great Lakes states would be expected to consume these
same species. It must be pointed out that the number of consumers in the total
population can be considered only ar. estimate because of the lack of information
on potential sampling error as well as other factors. These data indicated that the
99th percentile for daily consumption for all consumers of the selected species was
36.8 g; the 90th percentile for daily consumption was 15.7 g. For a single species
of fish such as pike, which appeared to be consumed in larger amounts than all the
species combined, the 99th percentile of consumption was 83.95 g. Table 1, which
is based on these fish consumption data, shows :he daily human consumption for
a range of hypothetical dioxin residue levels.
Thus, the four elements of the model for a scisn::f.c regulatory assessment, i.e.,
animal data, human data, consumption data, and residue data, were available. In
this instance the h u m a n data concerning TCDD exposure contributed little to the
regulatory decision because of the uncertainty of the exposure data as well as the

�386

FRANK CORDLE

uncertainty of the outcome of the exposure. It was necessary, therefore, to rely on
extrapolation from animal to human. In this case the rodent data from the 2-year
chronic feeding study (Kociba ei a/., 1978) were used for the extrapolation.
Results of that study showed that
(a) at 0.001 Mg/kg body wt/day, no adverse effects were noted in rats exposed
for their lifetimes to the dioxin;
(b) at 0.01 ng/kg body wt/day, hyperplasia of the liver and lung was observed
to occur, thus indicating an observable effect related to enzyme induction and liver
cell response to the compound;
(c) at 0.1 Mg/kg body wt/day, an increase in liver carcinomas was observed.
The animal-to-human extrapolation of the no-effect level for TCDD exposure
from the rodent data indicated an intake of 1 ng/'kg body wt/dav or a total daily
intake of 70 ng as the no-effect level. If fish containing average TCDD residue
levels of 25 ppt were consumed in the amount of the 99th percentile. i.e., 36.8 g/'
day. the total daily intake of TCDD would be 0.92 ng or 13 pg/kg body wt/day
or less than l/70th of the no-effect level, less than 1/700th of the lowest-effect
level, and less than 1 /7000th of the carcinogenic level. The safety margin at the
90th percentile of consumption is even greater.
As a result of this assessment, a public health advisory was sent to the health v
officers in each of the Great Lakes states, encouraging a continued mor.itoring of
TCDD residues in fish, especially in certain local areas where TCDD levels mightbe higher than the average, and where Local fish consumption might also be higher
than that for the Great Lakes area as a whole.
This exa.r.ple in regulatory decision making illustrates FDA's role in protecting
public health by ensuring a safe and nutritious food'supply. This responsibility is
exercised by individuals who call upon science, law, and the regulatory process to
accommodate the demands of safety, contamination, food requirements, Congress,
consumers, and the courts. Although the regulatory process has often been criticized, on the whole it has provided effective public health protection for the millions
who consume food in the United States.
REFERENCES
ALLEN. J. R.. BARSOTT;. D. A.. VAN MILLER, J. P., ABRAHAMSOS. L. L. AND LAUGH. J. J. 09").
Mcrp'-oiogica! changes in monkeys consuming a diet co.-.;aining low isvsis of ;.3.~.S-tei:ichlorodiber.io-p-c'ioxin. Food Cosmct. Toxicol. IS, 401-410.
COOK. R. R.. TOWNSEND. J. C. OTT. M. G.. AND SILVERSTEIN. L. B. (!9SO). Mor.a!h&gt; experience
. cf srspic.yeej exposed to :.j.T.S-ieirachioro&lt;Jib«.-i20-..--cio.\ir.. JO.'.f J. 0^-ap. .'•'&lt;::. 21. &lt;3C-&lt;21
HOLMSTSCT. B. 119SO). Prolegomena to Scveso. Arch. Toxicoi. 44. :i l-:;-0.
KOC:SA. R. J.. KsELER. P. A.. PARK. C. N.. AND GEMMING. P. J. H976). 13.7.&amp;-7j',ri:hic-:ociber.:op-cio.\in (TCDD;: Results of a 13-week orii loxiciiy s;udy in rats. Toxicol. Appl. Phsrn-.acol. 35,

553-574.
KOCISA. R. 1. KEYSS, D. G.. SEVER.-J. E.. CARRSON, R. M.. \VADE. C. £.. DITTENJIER, D. A..
KALMNS. R. ?.. FRACSON. L. E., PARK. C. N.. BARNARD. S. D.. HUMMEL, R. A.. AND HCMISTOS.

C. G. ('197*1. Results of a two-year chronic :oxic::y and oncng«riici:y jiucy o.f ;.3.7.S-;e::s&gt;ch!oro•iiber.io-p-dicxir. i.-..ra:s. Tbxifol. .*.,-,"!. Pksrmecol. 46. "9-?03,
McCosvaiJ.. £. E.. .'MOORE. J. A., AND DALOARO. D. W. (197S). Toxicity of :,3.7.S-ie:;achlorocibcr.^o-/i-cioxin (TCDD) ir. rhesus rnonl.eys (Macaco mvlci;a'i follow, jr.; 2 sir.gie orai dose. Toxieol.
Af-p!. Pns.'rr.cto!. 43, 175-187.
MUKP.AV. F.. J.. SMITH. F. A., SITSCHKE. K. D., HAMESTON. C. G., KocibA. R. J., AVD SC.HWETZ.

�EPIDEMIOLOGY AND REGULATION OF D10XINS

387

B. A. (.1979). Three-generation reproduction study of rats given 2.3,7.8-ietrachlorodibenzo-p-dioxin
(TOO! ir. '.he diet. Toxicol. Appl. Pharmacol. 50, 24J-252.
Orr. M. G.. HOLDER, B. B., AND OLSON. R. D- (1980). A mortality analysis of employees engaged
ir. the manufacture of 2.4,5-trichlorophenoxy acetic acid. JOM J. Occup. Mtd. 22. 47-50.
PA2DsROVA-V£JLUTKOv.v J.. NgWCOVA. M., PlCKOVA. J.. JlRASEK. L, AND LUKAS. E. (1981). The

oeveiopmem and prognosis of chronic intoxication by t«rachlorodibenzo-/&gt;-dioxin in men. Arch. En\-iror.. Heolih 36, 5-11.
PoccHiARi. F., SILANO. V., AND ZAMPIERI. A. (1979). Human health effects from accidental release
of tetrachlorodibenzo-p-dioxins (TCDD) a; Seveso. Italy. Ann. N. Y. Acad. Sci. 320, 311-320.
RECC:AM, G. U9SO). Acute human exposure to TCDD in Seveso, Italy. / Toxicol. Environ. Health
6, 2?-43.
ZACK. J. A.. AND SUSKIND. R. R. (1980). The mortality experience of workers exposed to tetrachiorodibenzodioxin in a trichlorophenol process accident. JOM J. Occup. Med. 22, 11-14.

�f. CooiU
Ajril H, t ^ S
PCOD INTAKE FOR DIOXIN, PCP LEVELS OF OONCESN

18-45yrs 2-5yrs
bw.71.2 bw.16.3

total red neat and poultry
Ibtal red meat

212g
108g

109.6g

Beef

134g

65.6g

Veal
Beef + veal

20g
136g

Lairb + mutton
Beef liver

17g
20g

Pork
Pork (45-64 years)

67g
75g

36^3g

8g

6.7

Pork liver
Poultry (total)
Poultry (total; 45-64 years)
Chicken
Chicken (45-64 years) -.•
Chicken liver
Turkey
Duck

'

53g
56g
44g
47g
13g
33g
17g

25.4g
4.4g'

Eggs
Ecgs( 45-64 years)

47g
58g

28.5g

Milk fat
Milk fat( 13-17 years)
Non-fat
railk
Ken-fat milk (13-17 years)

24g
31g
48g
74g

23.4g

�Samples collected fron Smith Farms (26 operating farms) en 1/17/83
Eggs
Eggs
Eggs
Eggs

- Farm £34
- K&amp;M Farm
- Farm #40
- Benders Farm

0.20ppm (PCP)
O.lSpcm (PC?)
O.~13ppm (PCP)

Feed
Feed
Feed

0.26ppn (PC?)

Feed

O.OSppm (PC?
0.07ppra (PC?)
Trace (PCP) .
Trace (PCP)

Food consumotion bv days and meals:
Beef
Perk
Chicken
Eggs
Milk fat
Other

18-45 years
134g X 5 ireals=670g
75g X 5 neals=375g
44g X 4 meals=176g
47g X 7 msals=329g
24g X 7 iTBals=168g

30g X 7 neals»210g

1928g

1928g/7=275.4g/day

2-5 years
55.6g X 5 meals=328c
36.3g X 5 neals=182g
25.4g X 4 m=alssl02g
.28.5g X 7 meals=200g
.23.4g X 7 nfials=174g
10.Og X 7 maals-TO^
1056c
1056g/7=151g/day

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                  <text>Alvin L. Young Collection on Agent Orange</text>
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                  <text>&lt;p style="margin-top: -1em; line-height: 1.2em;"&gt;The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.&lt;/p&gt;&#13;
&lt;p&gt;For more about this collection, &lt;a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a"&gt;view the Agent Orange Exhibit.&lt;/a&gt;&lt;/p&gt;</text>
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°1719

Author

Barnes, Donald G.

Corporate Author
Report/Article TltlO Memorandum: Suggested Procedures for Review of
CDC Protocol, from Donald G. Barnes to Members of
the Science Panel, July 1,1983

Journal/Book Title
Year

000

°

Month/Day
Color

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Descripton Notes

Monday, June 11, 2001

Page 1720 of 1793

�A

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

.$

WASHINGTON, D.C. Z0460

% na&amp;

JUL
OFFICE OF
PESTICIDES AND TOXIC SUBSTANCES

MEMORANDUM
TO:

Members of the Science Panel

SUBJECT:

Suggested Procedures for Review of CDC Protocol

The Science Panel has requested the assistance of the
Ranch Hand Oversight Committee in the review of CDC's
protocols of epidemiologic studies of the health of Vietnam
veterans. Based on conversations with Dr. John Moore, it
was agreed that the Science Panel would supply the Ranch Hand
Oversight Committee with a list of concerns that would focus
the Committee's attention on those issues which the Science
Panel feels are most urgent, with the assumption that the
individual committee members would be free to make any additional recommendations that they feel are appropriate.
The attached "Outline of Concerns" were drafted with the
cooperation of Major Bob Capell (USAF), Dr. Phil Kearney
(USDA), Jason Toth (EPA), and myself (EPA) after a telephone
conference last Thursday, June 23. In addition, Dr. Carl
Keller and Jason Toth, attended the Office of Technology
Assessment ' s review of the CDC protocols on Friday, June 24,
and felt it desirable to include a discussion of some of the
more generic aspects of the protocol. At the same time, we
do not want to discourage reviewers from missing this opportunity to comment on more specific aspects of the protocol.
We believe that our objective today should be to reach a
consensus among ourselves as to which general concerns are
most appropriately addressed by the Oversight Committee and what
the format for such a review should be. We recommend that individual Science Panel members use this same outline in structuring
their review of the protocols.

Donald G. Barnes, Ph.D.
EPA Representative to
Agent Orange Work Group
Chairman, Subcommittee on
Protocol Review

�Outline of General Concerns
I.

Background and Review of the Literature
Although the CDC literature review is relatively
current and appropriately takes advantage of previous
published comprehensive literature reviews, there is
relatively little discussion of the clinical experience
of the presently on-going Veterans studies. Recent Congressional testimony by Dr. Custis of the V.A. stated
that there have been over 350,000 Agent Orange related
outpatient visits, over 100,000 physical examinations,
approximately 20,000 veterans who have received more than
one exam and about 9000 Agent Orange related hospital admissions (May 1983). Although the physical examinations of
veterans conducted by the V.A. represent a self-selected
group, they nevertheless may provide a valuable data base
from which to refine and modify physical examination
protocols as well as providing reviewers with a basis for
evaluating the relative merits of individual studies.
1.

II.

Do reviewers feel that it would be desirable to
include a more thorough discussion of all relevant
on-going epidemiologic studies of veterans in the
final protocol, especially the V.A. Agent Orange
Registry examinations and any preliminary findings
of the Ranch Hand study?

Exposure Index
Accurately classifying Vietnam veterans with respect
to herbicide exposure is the single most important aspect
of this investigation, and CDC appropriately described
several reasons as to why these obstacles have been a
"formidable impediment to the accurate assessment of health
effects related to herbicide exposure" thus far. Nevertheless, CDC feels that the "Herbs" tape and other-available records are sufficient to make a reasonable determination of a veteran's potential exposure to Agent Orange.
It is not clear however, how the CDC intends to validate
this exposure index.

�-2-

1.

Do the reviewers have any specific recommendations for
validating the exposure index proposed by CDC (such as
crosschecking the pilot study sample against yet another
source of data or using a sensitive biological marker of
exposure)?
The second major concern with respect to classifying
veterans by potential exposure status is to investigate
the influence of all confounding exposures, particularly
combat experiences and insecticide exposure.

2.

Do reviewers have any recommendations for minimizing the
influence of confounding exposures?

3.

Do reviewers have any concerns or suggestions relating to
the sampling procedures and potential selection bias posed
by the proposed scheme for selecting study participants?
For instance, what are the potential consequences of
randomly choosing one day of the week and then selecting
study participants from company records? Would it be
desirable to estimate quantitatively the influence of misclassification bias in several hypothetical scenarios and
then recalculate power estimates?

III.

General Study Design
With respect to the rationale and general study design,
the case-control study of soft tissue sarcoma, the retrospective cohort mortality study, and the Vietnam experience
study all represent needed additions to the current Investigations of Vietnam veterans and appear to be relatively
straight forward. However, the assessment of morbidity
outcomes among Agent Orange exposed veterans is not as
straight-forward as the above studies.
The utilization of a one-time physical examination
and health questionnaire as the major instrument for
assessing health status has certain limitations, such
as: (1) missing those individuals whose overt manifestations related to Agent Orange exposure 15 years ago
may not have persisted until the time of examination;
(2) secondly, missing those individuals who currently
have no apparent physical manifestations of disease but
may nevertheless have subclinical metabolic changes of
medical significance which may not be adequately investigated during the exam; (3) and thirdly, some veterans
may not yet have had sufficient time to develop signs
and symptoms associated with Agent Orange exposure.

�1.

2.

A consistent recommendation made by the National
Research Council, the University of Texas and the
Department of Defense Armed Forces Epidemiological
Board in review of the Ranch Hand study was that the
physical and neuropsychological examinations should
be more refined by "evaluating a limited number of
morbidity endpoints, each in greater details." Do
reviewers feel that the clinical examination should
be expanded further to include more sophisticated
tests such as nerve conduction velocity or should
the clinical examination remain broad scoped unless
physical findings indicate more refined tests?
Do reviewers have any other suggestions for Improving
the clinical examination protocol?

3.

Do reviewers feel that it would be desirable for a
more thorough discussion of the rationale for those
tests whose purpose is not obvious, as well as a
discussion of the criteria that will be used to
evaluate the results of its pretests? Should the
results of of the pretests be a major check point
before proceeding with the rest of the investigation?

4.

Do reviewers feel that the proposed timetable is
overly optimistic?

5.

What are the consequences on the power of study to
detect potential adverse health outcomes if substantive
modifications of the protocol are made during the
course of the actual investigation?

6.

IV.

What is the cumulative influence of these considerations on the liklihood of detecting a true adverse
health effect attributable to Agent Orange exposure?
Would it be desirable to follow a subset of individuals
for a longer period of time, with periodic examinations
and updated questionnaires such as in the Ranch Hand
study?

Do reviewers feel that there needs to be a clearer
delineation between the pilot study phase and the
principal investigation?

Specific Concerns
A.
1.

Sarcoma-Lymphoma Study
What is the effect of non-uniform histologic classification of soft tissue sarcoma, especially if non-SEER
cancer registries are utilized?

�-4-

2.

Do reviewers have any suggestions for miniimizing
hypothesis testing problems posed by the simultaneous
investigation of multiple cancer sites?

3.

Are the power calculations of the ability to detect
a statistically significant elevation of cancer risk
based on appropriate data? For Instance, does the
protocol take into consideration the anticipated fraction of Vietnam veterans who were likely to have
been exposed to herbicides between the years 1963-1969
and are now living within the boundaries of participating SEER registries?

4.

Does the Committee have any recommendations concerning
the selection of controls or minimizing recall bias
among cases?

5.

Could this study be conducted more efficiently
and rapidly by closer collaboration with NCI and
their investigations of soft tissue sarcoma?
Alternatively, should all presently on-going casecontrol studies of soft tissue sarcoma utilize
CDC's questionnaire for investigating Vietnam Agent
Orange exposure?

6.

What are the relative advantages and disadvantages of
utilizing next-of-kin interviews of deceased cases,
thereby offering the possibility of completing the
study earlier than planned?

B.

Vietnam Experience Study

1.

Should this study be given more emphasis in view of
its potential to investigate "many factors in addition
to herbicide exposure which could have adversely affected those who served in Vietnam" as well as satisfying
veterans' demands for an investigation of compensatable
disabilities?

2.

Do reviewers have any recommendations which could
improve the ability of this study to investigate
the morbidity of veterans who had combat experience
but were not exposed to herbicides?

3.

Do reviewers feel that there should be a discussion
of how CDC's proposed Vietnam experience study relates
to the "Vietnam Veterans Mortality Study" and the V.A.
"Survey of Patient Treatment File for Vietnam Veteran
In-Patient Care?" For instance, could the power of
detecting conditions of low prevalence be improved
by combining all three efforts?

�-5-

Co

Agent Orange Study

1 &lt;&gt;

Do members of the Committee feel that the present ongoing CDC investigation of birth defects, which is
focused primarily on structural abnormalities, is sufficient to investigate all possible reproductive hazards?
If not, would a more detailed questionnaire or spouse
interview be sufficient to improve the investigation
of reproductive hazards in the present study or would
it be necessary to measure sperm count, morphology
or sister chromatid exchanges to investigate adequately
these endpoints?

2»

Should there be a much more detailed discussion of the
selection of tests for the neuro-psychologic examination?
Would it be possible to describe a psychological syndrome
or set of symptoms which have been reported most frequently
by the V.A. examiners (and in the literature) and then
investigate this "pattern" of symptoms more systematically?

3.

Do the reviewers have any further recommendations that
would improve the scientific validity of this study?
For instance, does the Committee have any recommendations
concerning the relative merits of CDC's efforts to
balance misclassification bias against comparability of
study participants?

4.

Do the reviewers feel that the CDC is being realistic
in their estimates of the number of physicals and
specialist examinations that could be conducted by
individual physicians?
Is it absolutely necessary to
examine all study participants at one or two centers,
or could blood samples and test results be sent to a
single laboratory for analysis, while at the same time
examining many more veterans at multiple facilities?
In order to minimize the inter-observer variation that
multiple examining centers would present, would it be
possible to develop strict clinical classification
criteria or to document suspected cases of chloracne
with photographs that could later be read by a panel
of specialists?

5.

Is there any way to include veterans who served multiple
tours without compromising the comparability of the
study participants or introducing too much selection
bias?

�-6-

V.

Overall Objectives and Purpose of Investigation
It is clear that the major impetus for the current
mandate by Congress (Public Law 96-151) to require the
Veterans Administration to conduct an epidemiological
investigation of U.S. veterans derives from the persistent
and legitimate demands of veterans' organizations that
the U.S. government investigate their claims for war
related disability compensation.
Although statements of
purpose such as "to assess the possible health effects
of exposure to herbicides and dioxin during the Vietnam
experience" can certainly be understood to encompass
the development of a data base from which such claims may
be evaluated, the stated objectives of the CDC protocol
do not reflect full cognizance of the potential problems
of interpretation and litigation that are likely to follow
a study of such complexity and controversy as this one.
For instance, Representative Thomas A. Daschle has sponsored
a special service-connected disability compensation bill
which contains a sunset provision to retract the presumption
of association for chloracne, porphyria cutanea tarda, and
soft tissue sarcoma if data from the ground troops study
does not confirm these associations. It would appear then
that there are expectations, which although legitimate may be
unreasonable, and it may be necessary to evaluate the objectives of the proposed studies within this context.
1.

Do reviewers feel that the proposed studies, either
individually or collectively, are sufficient to adequately
resolve compensation issues? Are there potential modifications which could improve the ability of this study
to resolve such issues?

2.

With respect to the stated objectives, will the proposed
studies contribute substantively to our understanding of
the adverse health effects of 2,4,5-T and dioxin exposure
among veterans?

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01733

Author

Barnes, Donald G.

Corporate Author
Roport/Artido TitlO Typescript: Comments on "Proportionate Mortally Study
of Army and Marine Corps Veterans of the Vietnam
War," Septembers, 1987

Journal/Book Titlo
Year

oooo

Month/Day
Color

n

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Doscrlpton Notes

Monday, June 11, 2001

Page 1784 of 1793

�9/8/87
COMMENTS ON
"PROPORTIONATE MORTALITY STUDY OF
ARMY AND MARINE CORPS VETERANS OF THE VIETNAM WAR"
Donald G. Barnes
U.S. Environmental Protection Agency
1. Proportionate mortality studies have inherent limitations
which restrict their interpretation and conclusions; e.g.,
reduced PMR in one area necessitates increased PMR in
another area. This particular study is a generally welldesigned example of this type of investigation. The report
clearly discusses the procedures, methods of analysis, and
the conclusions, including caveats. The results should not
be cited without an thorough appreciation of these caveats.
2. The study is a descriptive study which essentially suggests
hypotheses for further investigation. As such, the study
does not test any particular association, let alone prove
any cause-effect relationship.
3. It should be noted that of all the PMRs the two identified as
being of concern, while statistically significant, are
modest (roughly 2) — a tribute to the scale of the study.
4. Among the areas of concern is the question of whether there is
an inherent difference between Marines in Vietnam, compared
to non-Vietnam Marines and all Army troops. It has been
suggested that the Marines in Vietnam had attitudes and
behaviors (e.g., risk takers) which were distinguishable
from other troops.
5. The diagnosis of Non-Hogkins lymphoma is not easy. There
might be a bias in the recording of this diagnosis in cases
in which it was known that the patient had served in
Vietnam.
6. If one is concerned about the etiology of cancer vis a vis
Vietnam, it would be preferable to exclude any cancers that'
appear prior to some minimal latency period; e.g., 10 years.
7. It would be enlightening to look at the proportionate cancer
mortality ratios (PMCRs), which would examine the relative
cancer experience in greater detail.
8. Possible followups include:
a. An I Corps study of the Army veterans — planned
b. A periodic updating of the current study to take into
account latency, etc. — planned?
c. A cohort study of the Marines
d. A case-control study of the NHL and lung cancers in the
Marines.
The question of exposure still remains. Given the recent
results of the CDC exposure validation study, it is not
clear that options c and d are tenable.

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                    <text>Item D Number

°2409

Author

Barnes, Donald G.

Corporate Author
Report/Article TltlB Description of Times Beach, Missouri and the Times
Beach Dioxin Research Facility

Journal/Book Title
Year

000

°

Month/Day
Color

n

Number of Images

8

DeSCrbtOn NOtBa

Included in the description are maps of the area. Item also
includes an announcement of the paper "United States
Environmental Protection Agency's Approach to Dealing with
2,4,7,8-TCDD in the Environment."

Friday, October 05, 2001

Page 2409 of 2422

�UNITED STATES ENVIRONMENTAL PROTECTION AGENCY'S
APPROACH TO DEALING WITH 2,3,7,8-TCDD
IN THE ENVIRONMENT
Donald G. Barnes, Ph.D.
Science Advisor to the Assistant Administrator for
Pesticides and Toxic Substances
Chairman, Chlorinated Dioxins Work Group
US Environmental Protection Agency
Washington, D.C. 20460
In 1976, an explosion in Seveso, Italy focused the world's
attention on the environmental risks associated with 2,3,7,8TCDD.

Earlier, the United States had confronted related

condi-tjbns on a smaller scale in horse arenas in the state of
Missouri.

Since that time, the issue has grown in intensity and

complexity.

There are currently more than forty confirmed sites

of 2,3,7,8-TCDD contamination in Missouri, and several states
with reported contamination within their boundries.
In December, 1983, the United States Environmental
Protection Agency announced its "Dioxin Strategy", which
addresses the discovery and clean-up of contaminated sites,
research projects, and the significance of "dioxins" other than
2,3,7,8-TCDD.

In August, 1984, a major step in the

implementation of this strategy was taken with the announcement
of the National Dioxin Study.
This paper will review the Dioxin Strategy and the National
Dixoin Study, relating these to the past and continuing
experiences at Seveso.

�TIMES BEACH DIOXIN RESEARCH FACILITY

One of the conclusions of the Missouri Dioxin Task Force
was that further research needs to be conducted to determine
dioxin destruction methods.

The Missouri Department of

CO 55 Natural Resources (MDNR) recently assisted in establishing a

e&gt;2
C£
O
CO
UJ

c:

dioxin research group.

This group consists of governmental

agencies (MDNR, EPA, Missouri Division of Health), industry
and the University of Missouri.

This group also has concluded

that in-situ research at Tiroes Beach, Missouri, would be of
great help in determining destruction methods for dioxin
contaminated soils.

Based on the group's conclusions, the

MDNR is soliciting proposals for conducting in-situ research
on dioxin contaminated soil at Times Beach, Missouri,
beginning during the summer of 1984.

Li- £

Of

The objectives of this project are twofold.

The first is

to isolate those technologies that have potential to detoxify
dioxin contaminated material.

The second objective is to

compare different successful technologies for application to
solve the crisis.

Once potential technologies have been

identified, long-term funding mechanisms can be looked at for
those processes by the regulatory agencies.
Laurel Road in Times Beach, Missouri, has been selected as
the area for conducting in-situ dioxin destruction
investigations.

The street is bounded on the west and east

sides by Orchid Drive and Beach Drive, respectively (see
map).

The concentration of dioxin in soils is in the range of

100-300 ppb.
Christopher S. Bond Governor
Fred A. Lofser Director

Division of Environmental Quality
Robert J. Schrelber Jr. P£. Director

�The MDNR ectine on the suggestions of the research group
has set up the program by excavating a two block portion of
Laurel Road.

The soil and gravel were homogenized by mixing

them thoroughly.

The soil was then screened to remove the

larger gravel end rocks.

The screened material was then laid

back into stainless steel bins six feet by eight feet by two
feet deep and compacted back to the original density.

A

bottom liner was installed to drain liquids seeping through
the soil.
plot.

Water and power outlets are being provided at each

An on-site soils laboratory is also available.

*-

S e c u r i t y arrangements such as lockers and a d e c o n t a m i n a t i o n
f a c i l i t y are also a v a i l a b l e .

A f u l l - t i m e MDNR on-site

coordinator is a v a i l a b l e to oversee operations and ensure that
s e c u r i t y is m a i n t a i n e d .

Emergency services are also

available.
A comprehensive sampling and analysis program was
*

conducted to determine initial reference levels prior to
implementing research proposals.

The plots are currently

available for in-situ investigations.

The group has decided

that at least three units be made available per research
group.

This, would give the researcher an opportunity to

create a standard reference unit and vary parameters as
necessary

in the other two units.

Standardized soil could be

made available for in-house research, if the researcher
demonstrates that he has the resources for in-house management
of dioxin.

�During the investigation, close monitoring will be
maintained by the research group to assess the progress.

At

the end of the investigation, the group will review the
project's accomplishments and will take the appropriate
actions such as disbursing the information or recommending
that the process be applied at a given site.
Funding mechanisms for the program are being evaluated.
It is anticipated that the majority of the proposers would be
self-funded industrial entities.

The cost for leasing a plot

(set of three units) is $16,500 to be paid initially. This
*one time fee is essentially the cost of preparation of the
plot along with sampling and analysis costs before and after a
research project is complete.

This sampling and analysis will

provide MDNR verification of a project's success.
For further information, contact either Robert Schreiber
or Vivek Goswamy at (31*4) 751-32*41.

�TIMES BEACH

Location
Legal Description:

Floodplain of the Meramec
River, principally W 1/2, Sec. 32,
and E 1/2, E 1/2, Sec. 31, T.44 N.t
N., R. 4 E., 5th P.M.
Manchester Quadrangle
St. Louis County
Latitude: 38° 30' 33"
Longitude: 90° 36' 08"
Population 2,061 (None at Present)

Accessibility
Times Beach can be entered by any of three routes. Interstate 44 exits
onto a northern outer road which goes into the City. Lewis Road from the
north also connects with the 1-44 outer road. The third access route is
from the City of Eureka south of 1-44 onto Times Beach Service Road.
History Summary ,
In June 1972, a city ordinance was passed to contract with a waste oil
hauler to spray the roads for dust control. Apparently all of the gravel
streets were oiled that summer twice and a third time where needed, as recalled by residents. In 1973, the roads were again sprayed by contract.
The agreement was to have approximately ten miles of road oiled. Five
additional streets had been paved so less oiling was done that year. EPA
sampled the roads and right-of-ways in November and December 1982, and
found 2,3,7,8-TCDD levels up to 127 ppb. In December 1982, the Meramec
River flooded the town. EPA sampling in January 1983 following the flood
showed that the contaminated soil remained quite immobile throughout the
flooding. On February 22, 1983, the EPA Administrator announced a $33
million pledge from superfund to purchase the Times Beach property under
a relocation plan to be developed and implemented by the Federal
Emergency Management Agency (FEMA). EPA is planning to have a feasibility study conducted to determine the scope and costs of cleanup
alternatives. The city 1s on the National Priorities List.
Site Description (see maps)
Times Beach is principally bounded by the Meramec River, Interstate 44,
and the Burlington Northern Railroad tracks. Being in the 100-year
floodplain, the area is relatively flat. The majority of the city's 28
miles of paved and gravel road, shoulders, and ditches are contaminated.
Maximum levels of 2,3,7,8-TCDD are shown on the city map. Contamination has been found down to at least two feet below the surface. The
City of Eureka, population 3,862 lies Immediately to the south and west
of Times Beach. None of Eureka's streets were oiled and no contamination
has been found within the city. Results of all groundwater sampling in
the area have been negative.

�Geologic and Soils Description
Times Beach 1s on an alluvial setting, underlain by alluvial silt to a
depth of more than 5 feet. Below the alluvial silts; sand, gravel, and a
mixture of silt, sand, and clay would be expected to a depth of from 40
to 50 feet where bedrock 1s encountered. The water table would be expect:&gt; ed to be about at the Meramec River level, between 10 and 20 feet from
the surface in most of the area.
The alluvial silt has a relatively low permeability and would be expected
to be wet natured in that it does not readily or rapidly drain water.
Due to this and the screening effect of the silt, it 1s not likely that
soil particles contaminated with dioxin would move down Into the water
table.
It can be assumed that the contaminated material consists of road bed
material plus native soil where the contamination has eroded into the
ditches.

�ft^-7^^
LJrV-ts-xvtrSs..

MANCHESTER, MO.
&gt;

-

ka l

« Times
Beach-

Mapped by the Army Map Service
Published for civil use by the Geological Survey
Control by US6S. USCiGS. and USCE
Topography from aerial photographs by photogrammetric methods
Atria! photographs taken 1952. Field check 1954
f*o»yconic projection. 1927 North American datum
10.000-foot gric based on Missouri coordinate system, east zona
1000-meter Universal Transverse Mercator grid ticks, zone 15.
shown in blue
Dashed land lines indicate approximate locations
Unchecked elevations u* shown in brown
To place on the predicted North American Datum 1963
move the projection lines 2 meters_toutii and
10 meters east as shown by tesnee comer ticks

MM

«N

1000

nr I
if MIL!

VTM CHID AND tta: MAGNFTIC NOKTN
BCCUNATIDN AT CCNTEft OF SMCET

There may be private inholdings within
the boundaries of the National or
State reservations shown on this map

THIS
FOR SALE BY U. S. GEOL5
AN
MSSOtmt DF
A FOLDER OE$

�TIMES BEACH, MISSOURI
U.S. ENVIRONMENTAL PKOTECTlOM
REGION 7 - KANSAS CITY
183 «f3«9 Stmptec JUathtle •* of 2/4*1
vaKtr atturantc ^t^

LEGEND
Kit than I

- 10

UlllllK 20 - loo
100 - 300

•t f art» P*r

Y
© * ..
-.!

�</text>
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                    <text>item D Number

°5108

Author

Barnes, Donald G.

D Not Scanned

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'P ReP°rt Highlights and Analytical Chemistry and
Source Notes for the World Health Organization
Meetings in Naples, Italy and Copenhagen, Denmark,
March 15-27, 1986

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000

°

Month/Day
Color
Number of Images

D

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Descripton Notos

Friday, February 22, 2002

Page 5108 of 5115

�T R I P

R E P O R T
H I G H L I G H T S
WHO MEETINGS ON "DIOXINS"

Municipal Waste/Sewage Sludge Incineration -- Naples, Italy
Human Milk -- Copenhagen, Denmark
March 15-27, 1986
Donald G.Barnes
This report contains the highlights of the meetings. In
the coming days, I plan to prepare more extensive "discussion
papers" on the variety of topics list in item 8 below.
1. My presence at these meetings proved to be more important than
I first envisioned. As events unfolded, I was able to
contribute materially (perhaps "disproportionately" would
be a better descriptor) to the process, the substance,
and the outcomes of the meetings -- for better or worse!
2. Municipal Waste Combustion (MWC) and Municipal Sewage Sludge
Combustion (MSSC) Meeting
WHO-Geneva and WHO-EURO had/have an on-going tussle over
"who's in charge" of the CDD/CDF risk assessment issue.
At Geneva's strong encouragement, the Naples meeting
steered clear of a direct assessment of risk. Rather, we
developed what I would call a "relative exposure
assessment".
This entailed accepting certain calculations which have been
done to estimate the daily intake of 2,3,7,8-TCDD
equivalents necessary to maintain the apparent background
body burden; i.e., 1-5 pg/kg-d. Then we looked at how
much of this is likely to be coning from municipal waste
combustors (MWCs) and municipal sewage sludge combustors
(MSSCs). The analytical chemists gave us estimates of
the emissions from such units under best conditions, most
likely achievable conditions and anomalous conditions.
We concluded the following:
a. Direct inhalation of emissions from MWCs and MSSCs which
are operating at most likely or most likely achievable
conditions does not constitute a large contribution to
the daily background dose. Note: This is the only
exposure EPa generally considers.
b. Indirect contributions; e.g., via the food chain, are
unknown, but for a variety of reasons, are arguably
moderate-to-low.
c. Recent data indicate that the best case emissions can be
substantially improved by additional control technology.
d. The increasing number of sources of CDDs and CDFs which
are being proposed and/or identified in the environment
tends to lessen the actual contribution of MWCs and MSSCs
to the total impact.
There was a healthy discussion about the likelihood of any
effects in humans, given the epidemiological evidence to
date. The group deferred to the alleged recent judgment
of IARC that the evidence of human carcinogenicity for
-1 -

�2,3,7,8-TCDD has been elevated from "inadequate" to
"limited". However, there remained strong feeling that
the threat to humans is likely to be much less than many
currently believe based on animal evidence.
3. CDDs/CDFs/PCBs in Human Milk Meeting

The purpose of the meeting was to determine whether there were
any additional data/studies which should be
.-••• • .•. ••• ••; gathered/collected'prior to -conducting a risk assessment
on the CDDs/CDFs/PCBs in human milk issue late this year.
'•••' , "'We' concluded that we probably have now all that we will
have then. Therefore, we drew up an outline of what the
'•••'• report should look like:. ' • • '•''• ''•• : " ' ;
There will be three reports, individually drafted, that will
_-:. -•:. --feed into; one''maih paper: • : - ; '•' •'•' '••• •'•' :
a. Chemistry: Sources, residues data, and analytical problems
'-- b. Estimated'intake'of CDDs/CDFs/PCBs :
c. Epidemiology studies to be conducted in the long term
••"-!•. Hazard" Identification (Why'should anyone be concerned?)
A. Human data
'••' - 1 B.''Animal'data
'''" : '! 1J"^
C. Toxicity equivalents :
D. Uncertainties : ••'•' ' ' '' ' •'"•'
1. Link between sensitive effects in animals and anything
•'••'
''in' humans ' ' ' •'''• ' :' ' • '•• ' ' ;"'''' ' •' '"" '
2. Toxicity equivalents
•••'••" '•'• 3. Different mixtures
4. Etc.
II. Exposure Assessment
A. Sources
B. Estimated intake's and relative contribution of human milk
C. Historical trends
III. Benefits of Breast 'Feeding
IV. Preventive Strategies
A. What to do in the near term
B. Epidemiological study in the long term
V. Conclusions and Recommendations
4. WHO is interested in EPA's continuing to cooperate in the area
of CDDs/CDFs. Specifically, they would like to see EPA
contribute to the funding of a preparation of the report
on human milk.
Given the import and impact of the issue, I believe that the
Agency should stay actively involved with this project.
5. WHO-Geneva is producing criteria documents on both PCBs and
CDDs/CDFs. Several of us are reviewing the latter. We
should be assured that our overall participation is
appropriate, focused and sustained.
6. In the minds of some, the emissions of any combustion source
are qualitatively similar to those of MWCs. Therefore,
folks are speculating that MWCs many not be the main
source of CDDs/CDFs in the environment that some have

-2-

�envisioned. Other candidates include forest fires and
auto exhaust. Multiple, small combustors may constitute
a serious problem; e..g., hospital incinerators,
crematoria, and supermarket incinerators.
7. Dr. Chris Rappe will try to arrange a visit/seminar here at HQ
on April 17.
8. Subjects for future discussion papers (cf. #1):
a. Details on the MWC/MSSC decisions
b. Details on the human milk decisions
c. Notes on analytical chemistry
d. Current and pending governmental positions/regulations on
CDDs/CDFs
e. Human study in Sweden
f. Aspects of TEFs
g. Notes for the future
h. Risk assessment issues
i. WHO activities in this area
j. PCBs as an emerging old issue
k. PCP as an emerging old issue
1. Issues which remain unaddressed: metals emissions and
flyash disposal

-3-

�3/29/86

'

Don Barnes

ANALYTICAL CHEMISTRY AND SOURCE NOTES
Gathered During Meetings ,of
WORLD HEALTH ORGANIZATION
Held in Naples and Copenhagen
March 17-16, 1986
INTRODUCTION
The European Regional Office of the World Health
Organization (WHO-EURO) held meetings on the above dates to
consider two aspects of a three-year effort on "dioxins" and PCBs
(see separate report for more extensive information this larger
effort):
A. The health implications of the emissions of CDDs/CDFs from
municipal waste combustors (MWCs) and municipal sewage
sludge combustors (MSSCs).
B. Additional information which should be gathered prior to
conducting an assessment of the risk of breast feeding
newborns with milk contaminated with CDDs/CDFs and PCBs.
The major points of these meetings were contained in a
trip report submitted on March 28, 1986. The summary below,
dealing with analytical chemistry and sources, is one of several
summaries promised in the trip report which amplify on certain
aspects of and information gleaned from the WHO meetings.
Technique
Sampling spikes:
a. Following Rappe, Sweden has dictated that CDD/CDF
analysis should include addition of a labelled spike to
the sampling equipment (e.g., XAD-2 resin or urethane
foam plug). Final analytical results will be corrected
for the percent recovery of this spike, in a fashion
analogous to the correction made for the recovery of
spikes during the extraction and clean-up phase. Rappe
generally finds that the recovery is in the 30-60%
range, but see below. Therefore, there are three
spikes in the life history of every sample: the one in
the sampling device (4 congeners), the one added prior
to extraction and clean-up (3 congeners), and the one
added as a concurrent internal standard.
There was some discussion of the effectiveness of this
procedure, but, in summary, it did highlight the
question of the adequacy of the sampling phase of the
analysis -- which we often assume to be 100%.
b. Some investigators report that ambient air monitoring for
CDDs/CDFs has been effective only during the winter
months. Apparently, during the warmer periods of the
year, the sorbant material (e.g., urethane foam) does
not retain the analyte of the sampling spike which has
been added to check for efficiency of sampling.

-1 -

�Feeding studies
One lab took a large volume of flyash and homogenized it.
Repeated sampling from the large mass showed variations
in CDD/CDF content in excess of 100X.

Analysis of PCBs
a. Analysis of the PCBs is even more difficult than that
analysis of the CDDs/CDFs. The lack of standards for
the congeners, the difficulty in identifying the toxic
congeners, and the variable methods of analysis have
made it difficult to develop a standardized an
approach. However, within recent years there is an
emerging consensus about how many and which congeners
to quantitate and to use as a basis for quantitating
the amount of PCBs; e.g., 1 1 - 1 2 peaks, as opposed to
2-3 peacks. Therefore, the reported results of some
labs have decreased by a factor of about 2, simply due
to a different approach to analysis. Consequently, one
needs to closely examine reports of reductions in PCB
levels to be assured that these are not simply a
reflection of altered analytical approaches.
b. A WHO meeting in February recommended quantitating PCBs
based on about 7 peaks. However, only three of these
peaks have been found to any significant exent in human
milk; therefore, includng the othe other four in the
procedure may be irrelevant, if not expensive and
damaging.
Laboratory capabilities
a. It is estimated that there are roughly 10 labs in Europe
which have the ability to measure CDDs/CDFs at very low
levels. These labs are found in Sweden, the
Netherlands, Denmark, Germany, Norway, Italy (3-4), and
Finland.
Media
a. Rappe reports successful analysis of CDDs/CDFs in blood
in the low ppt range, starting with 150 ml of blood.
b. Rappe is conducting an inter-lab validation study for the
analysis of CDDs/CDFs in human milk. They have
collected a homogeneous sample of 10 liters of milk.
Given the complexity of uniformly spiking this much
material, each investigator will prepare his/her own
samples, using prepared aliquots of spiking solution
provided by the referee lab.
c. Cows grazing in the plume of MWCs are reported to have
higher levels of CDDs/CDFs than those grazing outside
the plume. However, there is some question about the
significance of this difference since the number of
cows is small and the difference between the two groups
of cows is not as great as one might think.
d. Rappe finds that the HxCDD/F fingerprinting found in
human samples matches the isomer pattern found in cows
-2-

�milk.
Sources
Air sampled in a Hamburg auto tunnel is purported to
display CDD/CDF emissions similar to those from MWCs -in fact, from any combustion source. This includes the
1,2,3,7,8-PeCDD, which had been thought to be a marker
for MWC emissions. At best, it is now a marker for
emissions from combustion sources, in general.
The three main contenders for the " Major CDD/CDF
Contributor" in the environment seem to be: a) MWCs, b)
automobiles, and c) PCP.
Several of the analysts believe that PVC will serve as a
legitimate source of CDD/CDF emissions in a MWC. This
is in contrast to the position set forth by FDA in a
recent EIS, in which they cite primarily one study in
which increased amounts of PVC in the waste stream did
not seem to materially elevate the CDD/CDF emissions.
I have conveyed this information to Paul Kaldjian of
the Federal Activities Office, who is coordinating the
EPA response to the FDA EIS. Note that an increased
possibility of CDD/CDF emissions is not equivalent to a
conclusion of a significant increase in health risk.
The pulp and paper industry in some parts of the world
are using an N02 based bleaching process, which
apparently is associated with CDDs/CDFs as well. In
addition, there is indication that some parts of the
industry use bromine-based slimicides; again, potential
sources of halogenated dioxins and furans.
I read the Kites article in the recent Environmental
Science and Technology and found it wanting.
Alledgedly, the article provides further evidence for
the combustion of chloro-organics as the source of the
CDDs/CDFs in the sediments of the Great Lakes. I did
not find the evidence of the explanation convincing.
First, the data displayed in the articles seemed, to
me, to argue strongly for a significant admixture of
higher CDDs/CDFs from pentachlorolphenol to any
contribution from combustion sources. Second, I found
some of the argument lack the clear compelling logic
one looks for in a scientific exposition. Instead, it
seemed that possibility and speculation in early parts
of the paper transmuted into "fact" later in the paper.
Further, I understand that there is some question about
the investigator's clean up procedures.
Hagenmaier (German analyst) still feels that the data
say "PCP" to him.
The Stiglitz experiment descrbed in Bayreuth has been
investigated by Hagenmaier. He has found a lot of
strangeness going on as he heats flyash at elevated
temperatures for a matter of hours. For example,
spikes disappear and there is a decrease in some
CDDs/CDFs and an increase in others. There is evidence
of the flyash's acting as a catalyst to facilitate
-3-

�g.

h.

i.
j.

k.

1.

m.

n.
o.

transformation of the higher CDDs/CDFs to the lower
ones.
Rappe has found that the homologue profiles may differ
from one combustion source to the next. However, he
has found that the isomer pattern (e.g., the
distribution of the TCDDs) is the same from one
combustion source to the next.
Note: This has implications for the application of the
estimation of 2,3,7,8-TCDD equivalents in risk
assessment. Ballschmiter says that "Everyone knows"
the percent of 2378-isomers within each homologous
group that are sampled from a combustion source. He
will sent me what "everyone knows".
Note: This may raise questions about the Townsend
explanation (cf., Bayreuth) for the origin of the
CDDs/CDFs in Midland soil samples.
Some folks feel that day-to-day variations at the same
plant could be 10X, making an assessment of the effect
of conditions and controls very difficult. Others did
not agree.
The general consensus is that, with current sampling
methods, it is futile to discuss the percent
partitioning between gaseous and particulate phases.
Rappe has not seen an increase in the CDD/CDF
contamination of the Baltic Sea organisms that matches
the increase of in the number of MWCs. This could
argue against MWC as the significant source, or it
could reflect more recent improvements in combustion
efficiency. Other potential sources include a) autos,
b) wire reclamation plants, and metal mills burning off
"cutting oils"; i.e., chlorinated paraffins.
I understand that Hagenmaier reported finding
2,3,7,8-TCDD in NaPCP produced by Dynamit-Noble at a
plant where trichlorophenol was produced. Further, he
has found 2,3,7,8-TCDD and 1,2,3,7,8-PeCDD in a sample
of Dowicide G. Finally, he found 2,3,7,8-TCDD in a
sample of 2,4-D. I have a preprint of the report which
has been submitted to Chemosphere.
Emissions from all kinds of incineration processes are
considered to be likely sources; e.g., hospital
incinerators, crematoria, and supermarket
incincerators. These are likely to be small in volume,
but their levels could be high.
OCDD has been found in essentially all samples of house
dust at a combined level of 70 ppb. A likely source is
PGP which is rather pervasive; e.g., these Hx-, Hp- and
OCDD have been found in toilet paper.
New automobile engine oil is reported has containing Hx-,
Hp- and OCDD. Again, this is suspected as having a PCP
origin.
An estimate of Hx-, Hp- and OCDD contributions to the
German environment:
800 kg/yr from MWC
250 Kg/yr from PCP use

-4-

�More than 1000 kg/yr from PCP waste
Controls
"Metals emissions from MWCs and MSSCs could be
troublesome. Swedish work seems to confirm our
understanding that most metals emissions will be
significatnly reduced by the controls designed to
reduce acid gases, particulate, and CDD/CDF emissions.
Sweden is developing a method to control mercury
emission, which seem to be among the most difficult to
control.
It would seem that metals control at the front end could
be more effective than currently practiced. Even
though some authorities have implemented input conrols
(primarily on batteries coming into the water stream),
these attempts have not met with resounding success.
Where are we in moving ahead oan this issue via RCRA,
TSCA, and CPSC?
Nomenclature
Rappe calls the "fingerprint" based on homologue-specific
data the "CDD/CDF profile" of the sample. The
"fingerprint" of the isomer-specific data, he calls the
"pattern" of the sample.
Tidbits
There is some indication of covalent reactions between
PCP and fat in vivo.
On a fat basis there is little, if any difference, in the
CDDs/CDFs or the PCB levels in fat, organ, milk, or
blood.
Folks are investigating the transformation between
homologues.
IPCS has apparently published a report on "Principles of
Risk Assessment in Infants".
Canada is doing flyash leachate studies.
Levels
Average PCB in background human milk fat: .5-1.5 ppm
" workers'
"
"
" : 3-15 ppm
The most prominent congener in milk fat is the
2,2',2,4,4',5-HxPCB
See attached list for the major and minor components of
PCDDs and PCDFs in human milk.
Reggiani, J. of Appl Tox 1_, 323 (1981) cites three
analyses of human milk by McKinney. We need to find
the original report.
Netherlands data on human milk will be released in April
and should add to the current picture.
PCP workers show an 85% decrease in their blood level of
OCDD within one year.

-5-

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                    <text>Item D Number

05720

Author

G

Barnes, Donald G.

Corporate Author
Report/Article Title Memorandum: From Don Barnes, US EPA, to Fellow
Members of the Agent Orange Working Group (AOWG)
Science Panel Distribution List, regarding Trip Report
on the Las Vegas "Dioxin" Meeting, dated November
13, 1987 with attachments

Journal/Book Title
Year

1987

Month/Day
Color

D

Number of Images

28

DOSCrlptOll NOtBS

Attachments include Trip Report, 7th International
Symposium on Chlorinated Dioxins and Related Compounds,
Las Vegas, Nevada, October 4-9,1987; and Program from
Dioxin '87: Seventh International Symposium on Chlorinated
Dioxins and Related Compounds, University of Nevada, Las
Vegas, Nevada, October 4-9,1987

Tuesday, March 26, 2002

Page 5720 of 5743

�11/13/87
RE:

Report on the Las Vegas "Dioxin" Meeting

TO:

Fellow Members of the AOWG Science Panel Distribution
List

FROM:

Don Barnes, US EPA

As you may recall, I was appointed, commissioned, and
otherwise ordained to be the representative of the AOWG Science
Panel at the Seventh International Symposium on Chlorinated
Dioxins and Related Compounds held in Las Vegas last month. As
such, I recieved and duly exercised all rights and priveleges
thereunto apertaining.
In order to steal -- and thereby limit -- my own thunder
when I file my report at the meeting of the Science Panel on Nov.
24, I am sending you a copy of my trip report. Those of you who
were at the meeting might want to examine this report as to its
completeness and accuracy. Those of your who were not at the
meeting might want to examine it as to its "originality, neatness
and aptness of thought." In either case, I promise to limit the
formal report on the 24th to less than one page.
Seriously, if there are topics/areas that any of you feel
merit further atteniton, I would appreciate your input.
Famous last words overheard at the conference: "I never
gamble when I come to Las Vegas. I keep all my assests in good
sound stocks...and I am doing very well, thank you."

�IQ/ 13/97

TRIP
R E P O R T
7th International Symposium on
Chlorinated Dioxins and Related Compounds
Las Vegas, NV
October 4-9, 1987
Donald G. Barnes
Highlights
A. Hazard Identification _
B. Dose-Response Assessment
C. Exposure Assessment «_
D. Risk Characterization
E. Control Technologies ___
F. Risk Management „_
. _
II. Technical Presentations
A. Plenary
B. Hazard Identification ^
1 . Human Data
2. Animal Data
3. Ancillary Data
C. Dose-Response Assessment
1 . Direct Potency
2. TEF-related Data
D. Exposure Assessment „
1 . Analytical
2. Sources (MWCs)
3. Sources (Other Than MWCs)
4. Transport and Fate
5. Environmental Levels
6. Human Tissue Levels
E. Risk Characterization
F. Control Technology
G. Risk Management
III. Scuttlebutt, etc.
IV. Personal Activities

-1-

P&lt;xg£
_
_
_
_
_

�I. HIGHLIGHTS
A. Hazard Identification
1. Human Data
a. No new human data were presented that would increase our
concern.
'
b. On the other side of the ledger, the 1986 CDC Missouri
"immunotoxicity anomaly" did not hold up under closer
scrutiny.
c. The NIOSH study remains the "last, best hope" of getting
something semi-definitive. It should be reported on
at the meeting next year.
2. Animal Data
a. Low level administration of OCDD for 13 weeks elicits
effects that begin to look like initial stages of
"dioxin" toxicity. Longer term studies need to be
conducted to verify the true "dioxin" toxicity; e.g.,
weight loss, thymic atrophy, etc.
b. High levels of some "non-toxic" CDD/CDF-like compounds
appear to act as antagonists for "dioxin" toxicity.
This may be a blessing for public health (God is good)
and a curse for risk assessment (How can this be taken
into account?).
c. The Univ. of Wise, monkey data was presented with
something of a flurry, including press reports. Some
effects (behavioral effects and learning deficits)
were reported. However, I think there was less there
than met the eye.
On the other hand, the analysis of the reproductive
effects in these animals suggests a NOEL of .05
ng/kg-d; cf. the Murray NOEL of 1 ng/kg-d.
d. 2,3,7,8-TBrDD and 2,3,7,8-TBrDF are 100x less toxic than
their chlorinated counterparts as measured in rabbit
ear and LD50 studies. There are implications of these
data for our mandated limit of detection for the TSCA
Section 4 D/F test rule.
3. Ancillary Data
a. No TCDD-induced DNA adducts were observed at a detection
of about 1 in 10**11.
b. More information was generated on metabolism of
CDDs/CDFs.
c. The receptor-mediated model of toxicity remains
generally accepted.
B. Dose-Response Assessment

»

t

1. The 3 order of magnitude spred in "the window" describing
international views of the potency of 2,3,7,8-TCDD
remains.
2. Relatively little research is being directed at examining
this issue. Each jurisdiction is basically maintaining
its position.
3. Some additional subchronic, whole animal data have been

-2-

�generated. The TEFs generally agree with these results,
with some exceptions which should probably be addressed.
A previous detractor of the TEF approach has generated
data that supports the approach. However, vitamin A
reduction does not seem to follow the TEF predictions.
4. The NATO CCMS group is proposing a common set of TEFs for
everyone.
C. Exposure Assessment
The majority of papers at the conference were devoted to
analytical chemistry, sources, fate and transport, and
levels.
1. Analytical chemistry
a. Biological analyses (Safe, Gierthy, and Poland) are
viewed as competing favorably with GC/MS in detection
limits. In addition, these approaches seem to
integrate the total biological response; i.e., these
approaches might even be better for analysis of
mixtures. Gierthy's analysis has been effective in
assessing fish, following a cleanup which is less
extensive than that needed for GC/MS.
The Agency should move smartly to complete the mission
of developing these approaches to replace the TEF
method.
b. The waxy cuticles of some leaves contain CDDs/CDFs which
may reflect airborne levels of these compounds. This
could be important both for monitoring purposes and
for risk assessment — if those leaves happen to be
cabbage leaves, etc.
c. The detection limit of .1 ppb for the HDD/F TSCA rule is
unattainable (according to some folks) due to the
overlap of the BrDDs with the brominated
diphenylethers in the clean up.
d. Infrared techniques can now detect and determine
structure of CDDs/CDFs in the ng range.

&gt;

2. Sources
a. Sources receiving more than usual attention this year
included
Pulp
Paper (1986 German work found 2,3,7,8-TCDD in tissue,
coffee filter, and newsprint)
Automobiles -- CDDs/Fs, BrDDs/Fs, and mixed
C/BrDDs/Fs. (In all, there are more than 5000
chemicals in this family -- which is enough to make
even the best analytical chemist blanch...and then get
a gleam in his eye!)
Burning of straw — which has .1% natural Cl
Home heating
b. We are likely to find other sources. However, we
probably has found most of the "biggies". There is a
need to put these sources into relative perspective.
c. De novo synthesis of CDDs/Fs from C, Cl and "clean"
-3-

�flyash has apparently been shown.
3. Transport and Fate
a. Evidence is being gathered that supports the notion of
long range transport of CDDs/CDFs by air.
b. Hutzinger believes that aerial deposition/collection in
leafy plants is a more important exposure route to
humans by direct ingestion or via grazing animals than
is soil uptake by plants or sediment/water uptake by
fish.
c. Consensus is emerging on the half life of 2,3,7,8-TCDD
at 5-8 years. (Yes, Dr. Poiger was there again
looking fit and, theoretically, with only 750 pg of
his original 1000 pg of labelled 2,3,7,8-TCDD. He
says he has not acquired a taste for more.)
d. 2,3,7,8-TCDD may be a major sink for the
photodegradation of OCDD.
e. Freeman and Schroy now agree with Yanders on the
volatilization of 2,3,7,8-TCDD from soil; about 100X
less than they had previously said.
f. Vapor phase 2,3,7,8-TCDD photodegrades in solar
wavelength UV.
g. There is a lack of correlation between modeled
dispersion and environmental samples of CDD/F
emissions from a "dirty" MWC. This raises questions
about the model or the sampling.
h. Chloranil is apparently a source of CDDs and CDFs.
Therefore, are we addressing chloranil?
4.. Levels
a. There is growing consensus that there is a background
level of CDDs/CDFs in humans, which in Western
societies is roughly 10 ppt on a lipid weight basis.
b. This body burden is probably being maintained via a
dietary intake of 1 pg TEQs/kg-d. Ingestion of beef
is viewed by many as being the principal component in
the diet
c. High body burdens of CDDs/CDFs are markers for high
exposures; in some cases, for exposure which occurred
long ago.
d. A limited review of pooled samples of human milk in
Sweden suggests that levels of TEQs have dropped by
60% over the last decade. (Note that Sweden has
eliminated use of chlorophenols during this time.)
D. Risk Characterization
1. Only a few true risk characterizations were presented:
human milk, pulp and paper sludge use in land
reclamation, and occupational exposure limit.
2. It is clear that more needs to be done in dealing with
uncertainties. The human milk effort was notable in that
&gt;
it used three approaches: extrapolation from animals,
comparison to human data (Yusho/Yucheng patients), and
-4-

�background levels.
3. There is a real need to link up the analytical chemists and
the exposure modellers in order to validate some of the
remarkable predicitons which can now be made.
4. Kay Jones's analysis suggests that the difference between
"worst case" homologue-specific assumption (all congeners
are 2378-substitute'd) and the isomer-specific data is
more than 10X.
E. Control Technology
I did not attend these sessions; however, it is my impression
that USEPA is in the lead in these matters.
F. Risk Management
Success has been met in some instances; e.g., portions of the
Missouri problem. Good risk management does not happen
without good risk communication.
G. Other
Some folks are using "congener" where we use "homologue".
goodness!

-5-

Oh,

�II. TECHNICAL

PRESENTATIONS

See attached list of papers and posters.
Full abstracts are available.
Papers will be published in Chemosphere next year.
A. Plenary
1. Hazard Identification — Steve Safe (Texas A and M)
The 5000X spread seen in LD50 in different species is
larger than that seen for other toxic endpoints.
The AHH induction assay correlates well with subchronic
responses. (Isn't it time that we began to move away
from TEFs and toward this approach?)
Good antagonists are those which have high binding
affinity to the receptor/ but do not turn on the
responses; e.g., AHH. These include Aroclor 1254, PCBs
and 1,3,6,8-TCDF.
Antagonism also seen in immunotoxicity endpoint; i.e.,
sheep red blood cell (SRBC) plaque-forming assay.
2. Dose-Response -- Bob Scheuplein (FDA)
Listed all the difficulties with modeling.
Sielken makes some good points; cf., Food Cosmet. Tox.
article. Wee need to address this substantively.
The Moolgavkar model makes testable predictions. The LMS
does not.
3. Exposure (Analytical and environmental levels) —
Christopher Rappe (Sweden)
There are 5020 chlorinated and brominated Ds/Fs and they
are being found in the environment.
We need to look at "homologue profiles" (e.g., histograms
of TCDDs vs. PeCDDs vs. HxCDDs, etc.) and "isomer
patterns" (e.g., histograms of 2,3,7,8-TCDD vs.
1,3,6,8-TCDD vs. 1,2,3,4-TCDD, etc.) The patterns may
be more indicative of source than are the profiles.
The emission patterns from a number of combustion sources
are essentially the same; e.g., MWC, automobiles, and
PVC pyrolysis.
Tissue levels
Essentially the same in US, Sweden, Germany, Japan and
South Vietnam
Relatively lower in Chian and North Vietnam
In general for CDDs: T Pe Hx Hp 0
In general for CDFs: T Pe = Hx Hp 0
Special cases
Spanish family who ingested contaminated olive oil
Level in the blood for OCDD is about 1 ppm'!
A girl who died at 6 days old had levels just a bit
below background.
Routes/sources of exposure
Dermal:
Low
Inhalation: .1 pg TEQs/kg-d
Ingestion:
1 pg TEQs/kg-d
Nursing:
70 pg TEQs/kg-d

-6-

�4. Exposure (Sources, fate and transport) -- Otto Hutzinger
(FRG)
Home heating and automobiles have been underestimated as
sources of CDDs/CDFs. He suggested that home heating
emission would be about equal to the MWC fly ash.
84 chlorinated chemicals have been analyzed for Ds/Fs in
Germany. Their analytical criteria were "under 2 ppb
for 2,3,7,8-TCDD and under 5 ppb for all of the other
toxic CDDs/Fs". OCDD was found in many places,
including aliphatic compounds. He suggested a "Trace
Chemistry of Cl" theory for predicting the presence of
OCDD; i.e., wherever you have Cl, you are likely to
find OCDD.
Possible sources include
a. Chloroaromatic precursors
b. Chloroaliphatic precursors
c. Pyrolysis of natural precursors; cf. lignon and Cl
d. Formation from ethylene units; cf. organics and Cl
Combustion air could be source of feed materials leading
to CDD/F emissions. See ES and T article.
The amount of CDDs/Fs (mostly OCDD) in the needles of a
Christmas tree is about 1 ug, or 3 kg in all of the
trees in Germany. This compares to 3-4 gm TEQs/yr from
automobiles.
5. Risk Characterization -- Barnes
Hard copy of slides available. (Golly, they're swell!)
6. Control Options -- Tom Hauser
Has a good one page summary of approaches. See des
Rosiers.
7.'Risk Management — Boddington
Ontario has a different SF for assessing 2,3,7,8-TCDD in
air compared to fish. [Note: I would express this as
saying that the risk managers had decided to accept
different margins of exposure (MOEs) in the two cases
in reaching their "regulatory dose (RgD)".]
We do more crisis management than we do risk management.
In fact, we should be doing more issue management,
since we really don't know what the risk is. [This is
a good thought which should be more fully developed and
discussed.]
We all know that funding does not support low profiles
projects.
B. Hazard Identification (Papers in Epidemiology,
Mechanism-of-Action, Animal Toxicology, and selected
posters)
1. Human data
a. EP01 — "Use of Phenoxy Acid Herbicides in Sweden"
A attempt to correlate production and use figures.
Only a small portion was contaminated with
2,3,7,8-TCDD.
b. EP02 — "Risk of STS, Hodgkin's Disease and NHL Among
Swedish Licensed Pesticide Applicators"
-7-

�c.

d.

e.

f.

g.

h.

i.

j.

Small study of about 300 out of a cohort of 20,000.
Mean follow-up time was 12 yrs. Relative risk:
For STS, 6 (obs)/6.4 (exptd) = .94
For HD, 11 (obs)/9.1 (exptd) = 1.20
For NHL, 21(obs)/20.8(exptd) = 1.01
For the latter two, there was a non-significant
increase with time since license.
EP03 — "NHL Among Phenoxy Acetic Acid Herbicide-Exposed
Farm Workers in WA State"
Some "blips", particularly for other chemical
exposures; e.g., chlordane, DDT, organic solvents and
arsenic compounds. Nothing sticks out for 2,4-D and
2,4,5-T. There was adequate power to detect 1.3-fold
excess risk. (Shiela Hoare commented that her study
had detected 1.4-fold excess risk to those who had
been exposed for more than 10 yrs.) "These
results...do not implicate phenoxy acetic acid
herbicides or their contaminants alone as sufficient
causes for NHL..." The author noted that there could
be a promoter or a co-carcinogen active here.
EP04 — "NHL, STS and Exposure to Phenoxy Herbicides in
New Zealand: Relationship to Frequency and Duration
of Exposure"
:
Withdrawn
EPOS -- "Follow-up of Chloracne Cases Following TCDD
Exposure at Seveso"
The abstract states: "...shows the absence of effects
other than chloracne and its whole reversibility in
the Seveso population."
EP06 — "... Seveso...and Ten Year Mortality Experience"
The abstract states: "...suggestions of an increased
risk of cardiovascular diseases shortly after the
accident and of a later possibly increased mortality
from liver cancer in selected subgroups were
obtained."
EP07 — "Spontaneous Abortion and Exposure to Emissions
from Waste Electrical Products Combustion"
I didn't hear this paper from Taiwan, but the abstract
states that "...former study shoes that pregnant
women in polluted area have higher prevalence rate of
spontaneous abortion." The abstract promises more
info in the presentation.
EP08 — "Medical Follow-up of the Health Effects of
Long-Term Exposure to 2,3,7,8-TCDD"
Failure to confirm the original (flawed?) study which
reported immuntox effects in exposed folks in
Missouri. Includes a somewhat generous discussion of
what might have gone wrong and suggests additional
study. (Heaven help us!)
PS12 — "Case-Control Study of Women Giving Birth to
Deformed Babies and on Patients Having Hydatiform
Mole in the Obstetrical and Gynecologic Hospital of
Ho Chi Minh city in South of Vietnam"
PS 13 — "Retrospective Study on the Incidence of Birth
-8-

�k.
1.

m.

n.

Defects and Other Reproductive Anomalies in the
Obstetrical and Gynecological Hospital of Ho Chi Minh
City"
PS23 — "Surveys on Incidence of Reproductive Anomalies
in Herbicide-Sprayed and Non-Herbicide-Sprayed
Villages in the South of Vietnam"
PS28 -- "Lab Assessment of Immune System in Individuals
Occupationally Exposed to 2,3,7,8-TCDD: Test
Selection, Assay Methods, and QC in a Cross-Sectional
Epi Study"
Preliminary work to determine the variation in the
endpoints. It is going to be hard to interpret,
given the intra-individual variations in these
endpoints.
MA06 -- "Humans Exposed to PCBs and PCDFs Exhibit
Increase SCE Frequencies in Lymphocytes When
Incubated with a-Naphthoflavone (ANF)"
The presence of ANF increases the frequency of observed
SCE in a blood cultures. True for smokers vs
non-smokers. True for Yucheng patients in which the
blood concentrations were 15 ppb for PCBs and 14 ppt
for PCDFs. It is thought that the pollutants result
in greater metabolism of ANF to genotoxic
metabolites. Note TCDD receptor concentrations: rat
lymphocyte -- 2 fmol/mg; human lymphocyte -- .3
fmol/mg. ANF assay also active with Chinese hamster
ovary cells and TCDD induced liver microsomes.
ANF-DNA adduct detected (but see lack of adducts
noted by Safe). Phenobarbitol is not effective, even
with ANF. P-450c is implicated.
MA15 -- "Placental Markers of Human Exposure to PCBs and
PCDFs"
Placentas obtained 4 years after exposure in Taiwan.
Marked AHH activity (10-1 OCX). Significantly lower
EGF stimulated receptor autophosphorylation,
correlating with decreased birthweight. However, no
alteration in EGF receptor binding kinetics. Only
very low concentration of specific binding sites.
This suggests "...that the potent AHH induction can
occur in humans in the absence of high concentrations
of the Ah receptor" (cf., similar receptor
concentrations in species of differing
susceptibility). Marked elevation of some PCBs and
PCDFs in the placental tissue; e.g., 2,3,4,7,8-PeCDF
(120 ppt) 1,2,3,4,7,8-HxCDF (380 ppt), and some PCB
isomers at a ppb. "Total PCB values might be better
predictors of response than PCDF values following
human exposure..."

2. Animal data
a. AT01 — "Interleukin 1 Responsiveness and Production in
2,3,7,8-TCDF-Treated Mice"
Response of thymocytes to IL-1 used as a probe for
2,3,7,8-TCDF treated mice. Perinatally exposed
-9-

�animals compared to postnatally exposed. Some
effects seen.
AT02 — "Behavioral Effects in Monkeys Exposed to
2,3,7,8-TCDD Transmitted Maternally during Gestation
and for Four Months of Nursing"
This is a follow-up of the Allen work.
"There were no
observed physiological indications of toxicity in
either the mother monkey or their offspring..." Fat
data are reported: e.g., offspring of the 5 ppt moms
had about 350 ppt, while those from 25 ppt moms had
370, 760 and 1350 ppt.
Certain social behavioral differences are noted; e.g.,
"...increased maternal care of the [treated]
offspring..." A series of "learning data" were
present allegedly showing some sort of D-R
relationship. This is strange stuff, however; e.g.,
for some effects the trend is up with dose, for other
effects the trend is down with dose. In nearly every
case, the responses of the treated animals are within
the range of the controlsi During the Qs and As, the
author (Bowman) characterized the learning data as
"Not strong, subtle".
For me, this is some interesting, preliminary data for
"... a relatively new area of research in which the
methodology is still at an early stage of
development". It certainly doesn't seem to be the
type of thing that would support a story in a San
Francisco newspaper.
AT03 -- "Chronic Dietary Intake of 2,3,7,8-TCDD...:
Kinetics and Dose-Effect Estimate of Reproductive
Toxicity"
The abstract indicates that a lot of tissue (fat/milk
from mom/kids) have been gathered. Mom's fat cone of
2,3,7,8-TCDD is less than that of the kid. However,
the moms' levels are proportional to the kids'.
There is a 20-30% transfer of mom's body burden to
the kid via nursing. Begin to see toxic effects in
animals having a fat level of 200 ppt. Apparent
half-life is a bit over a year. An index of
reproductive success was developed. (Comment,
anyone?) Extrapolation suggests a NOEL of about .05
ng/kg-d. (This is 20X lower than the Murray NOEL of
1 ng/kg-d or the level used by CDC, derived from
these same monkeys at an earlier date.)
AT04 — "Increase in Epidermal Langerhans Cells in Mouse
Skin Following Treatment with TCDD"
Langerhans cells are strange little fellas, 'being
immunologic cells of skin. Contrary to expectation,
these cells increased 3-4X following treatment of the
skin with 2,3,7,8-TCDD. In vitro, both the haired
and the hairless mice responded to the chloracnegen.
In vivo, however, only the hairless responded. Note
that phorbol esters also stimulate Langerhans cell
proliferation in hairless mice.

-10-

�AT05 -- "Metabolism of Some PCDFs in the Rat"
Chemicals studied: 1,3,7,8-TCDF
2,3,6,8-TCDF
1,2,3,4,8-PeCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
' 1,2,3,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
Breaking the ether linkage is tough. Metabolism of the
persistent 2,3,4,7,8-PeCDF is complex. The Hx- and
Hp- are not metabolized very much.
AT06 — "Subchronic Toxicity of some PCDDs/PCDFs in the
Rat"
Compounds studied: 2,3,7,8-TCDD
TEFs: 1.0
1 ,2,3,7,8-PeCDD
.4
1,2,3,4,8-PeCDF
.001
1,2,3,7,8-PeCDF
.01
2,3,4,7,8-PeCDF
.4
1,2,3,6,7,8-HxCDF
.1
13 week studies. A variety of endpoints examined.
Differences were noted in the manner in which the
compounds distributed in the body.
Tests with mixtures showed that additivity holds.
(Safe predicts that antagonism would be seen if
non-toxic congeners were also used.)
AT07 -- "Relay Toxicity Study with a Mixture of PCDDs
and PCDFs"
This was presented as a poster session, which I did not
see. However, the abstract talks about feeding
flyash to rabbits, excising the liver, extracting the
CDDs/CDFs from the liver, analyzing by GC/MS, and
feeding the extract to rats. The toxicity predicted
by their TEFs were in good agreement with the results
of the rat study.
This marks a change in the Suter-Hoffman stance in that
she now finds that the TEF approach (using factors
somewhat different from EPA's) works rather well,
thank you. The toxic effects of the CDDs/CDFs in
mixtures appear to be additive.
AT08 — "Effects of Combinations of PCDDs/PCDFs Given to
Rats"
Vitamin A reduction does not seem to follow the TEF
predictions very well.
AT09 — "Is the TCDD-Induced Embryotoxicity in Rats Due
to Maternal Toxicity?"
Yes, and principally.
AT10 -- "2,3,7,8-TCDD Induced Alterations in Vitamin A
Homeostasis and in the EROD Activity in Rats and
Guinea Pigs"
Lots of data, including the fact that rats can recover
when guinea pigs can't.
AT11 -- "Distribution of 2,3,7,8-TCDD between
Parenchymal and Non-Parenchymal Rat Hepatic Cells and
Its Effect on the Vitamin A Content of These Cells"

-11-

�"...long-lasting inhibition of the normal vitamin A
accumulation occuring in the stellate cells..."
1. AT12 -- "immune Abnormalities Associated with Chronic
TCDD Exposure in Rhesus"
"...these immunological alterations are not global, nor
are they of such severity that an immunodeficient
state of major clinical significant is
apparent...[Tjhere have been no clinical
manifestations consistent with major loss of a host
defense system...[T]he observed immunological
alterations occurred quite consistently in the mother
carrying the higher levels of TCDD in fat for years
after the exposure."
m. PS44 -- "Two-dimensional Polyacrylamide Gel
Electrophoresis of Liver Microsomal Proteins from
Rats Treated with 2,3,7,8-TCDD, 3-Methylcholanthrene,
and Phenobarbital"
Characteristic patterns developed.
n. PS69 — "Response of Murine Skin to 2,3,7,8-TCDD:
Comparison of Haired and Hairless Genotypes"
Response of newborn mouse skin to TCDD was similar to
that of adults. Also looked at some skin enzyme and
added treatment with other chemicals.
o. SE16 -- "Investigation of Comparative Toxicity of
[Flame Retardant Treated Plastics] Using
2,3,7,8-TBrDD and 2,3,7,8-TBrCF as Positive Controls"
By the LD50 test and by the rabbit ear test, the TEFs
for the brominated analogs are .01 or less. There is
some question about portions of the experiment, but
apparently BrDDs are formed a non-detectable levels.
However, the BrDFs have a pretty good yield; e.g.,
.1%.
3. Ancillary Data (Mechanism-of-Action and selected posters,
including information on physical properties)
a. MA01 — "Evidence for the Formation of Chlorinated
Biphenyls, Phenoxyphenols and "Dioxins" Upon
Metabolism of 2,4,5-TCP in Rat Liver S9-Fractions"
Apparently, a hydoxylated HxCDD has been detected in
this in vitro experiment which is not observed in the
absence of the S9 fraction. Previously, this
biochemistry had only been observed in a fungus.
b. MA02 — "A Physiologically Based Pharmacokinetic Model
for 2,3,7,8-TCDDrt
The model was developed using data from the C57B6 vs
the DBA vs rat. It estimates tissue distributions in
terms of organs volumes, blood flow rates,' etc. It
postulates two groups of liver binding proteins; cf.
cytosolic receptor and the microsomal monooxygenase
system.
c. MA03 — "Elimination and Pharmacokinetic Interaction of
some PCDFs in the Liver the Rat"
Half lives: 1,2,3,7,8-PeCDF 3.3 days
2,3,4,7,8-PeCDF 108 days; longer than

-12-

�2,3,7,8-TCDD
1,2,3,6,7,8-HxCDF
61 days; "
"
"
"
First order kinetics. No interaction in binary mix.
MA04 -- "Selective Retention of PCDDs and PCDFs in
Mammals: A Multiple Cause Problem"
Posits that more than differential metabolism is
involved. Suggests "...primary involvement of
carrier-protein(s)...". Similar thoughts as MA02.
MA05 -- "Liver DNA Alterations by 2,3,7,8-TCDD and
1,2,3,7,8-PeCDD in Female Rat"
This was an investigation of "l-spots", liver
alterations which have been suggested as sites of
spontaneous initiation. Both the TCDD and PeCDD
dosing led to a decrease in the concentration of
these I-spots. Hmmm.
MA07 -- "Effects of 2,3,7,8-TCDD on Enzyme-Altered Foci,
Hepatocellular Tumors, and Estradiol Metabolism in a
Two-Stage Hepatocarcinogenesis Model"
Ovarectomized rats did not yield the Pitot-like
promotion of DEN-initiated rats. Studies with whole
rats indicated that DEN potentiates estradiol
metabolic effects of 2,3,7,8-TCDD. There is some
confusion about what this means regarding the
promotion behavior of the compound.
MA08 — "Potentiation of the Toxic Action of
2,3,7,8-TCDD by Some PCBs, as Assessed by
E.I.S-bioassy"
Extension of bioassay using fish to examine TEFs.
Several unanswered questions about the study remain.
MA09 -- " Inhibitory Effect of Methylsulphonyl PCBs on
AHH Activity"
These chemicals are human metabolites of PCBs found in
Yusho patients. Surprisingly, they reduced AHH
activity.
MA10 -- "Aroclor 1254 as a 2,3,7,8-TCDD Antagonist in
Mice"
Safe's report of his work. Effects noted in
immuno-assay. Also development of cleft palate.
MA11 — "Effect of TCDD and Comparable Inducers Upon
Synthesis and Mono-oxygenase Molecular Forms P-450c
and P-450d Among Mammals"
The first Russian contribution at these conferences.
TCDD microsomes have a low content of P-450c but have
much higher benzpyrene-hydroxylase activity than the
enzymes induced by other "MC-type" inducers.
MA12 -- "Dynamic Comparision of Rat Liver
Benzpyrene-Hydroxylase Induction by 2,3,7/8-TCDD and
3-MC"
A kinetic investigation of the previous paper.
MA13 -- "Kinetic Models for Association of 2,3,7,8-TCDD
with the Ah Receptor"
Usual determinations of dissociation constant of the
receptor complex assume equilibrium. Due to the
rapid dissociation of the unbound receptor, this

-13-

�m.

n.

o.

p.

q.

r.

assumption is likely to be incorrect. An alternative
method of determining the dissociation constant leads
to values for Kd which are two orders of magnitude
less than previous values; i.e., the complex is
"tighter".
MA14 — "TCDD Mediated Decrease in Dexamethasone Binding
to the Hepatic '"Glucocorticoid Receptor is Not
Accompanied by a Decrease in Immunodetectable
Glucocorticoid Receptor Concentrations: The Role of
Adrenal Steroids"
Adrenalectomized rats are more sensitive; therefore,
"...circulating adrenal hormones may exert a
protective role in modifying the animal's response to
TCDD..." TCDD reduced the number of glucocorticoid
receptor binding sites, but did not affect the
concentration of the protein itself. The role of the
Ah receptor is being investigated in "susceptible"
and "unsusceptible" mice. The hypothesis is that
this effect is separate from the Ah receptor
mechanism.
MA16 — "Comparative Effects of 2,3,7,8-TCDD and
Progesterone on Estrogenic Responses in Rats"
Both lead to decrease in estrogen receptor.
2,3,7,8-TCDD also reduces the level of progesterone
receptor. The pathway of 2,3,7,8-TCDD activity is
different from that of progesterone.
PS08 -- "Prediction of Vapor Pressures, Boiling Points
and Enthalpies of Fusion for 29 HDDs and 53 HDFs by
Vapor Pressure Correlation Method"
Data from 14 CDDs/CDFs led to predictions for a number
of other C1-, Br-, I-, F- and mixed DDs and 53 CDFs.
PS41 — "Solubility Studies Using a Generator Column for
2,3,7,8-TCDD"
Solubility of 13 ppt determined at 4 degrees C.
Solubility at 25 degrees was much higher (over 100
ppt?) These values differ from the 1986 value of
Marple, which EPA is citing these days. This wide
variation in the literature cautions against our
using any value as a "real number".
PS48 — "Molecular Geometry Approximations for CDDs by
Fourier Transform IR Spectroscopy"
Vapor spectra of 14 different CDDs. Calculated COG
bond angles to determine geometry. Ranged from
nearly planar for lateral substitution with high
electron withdrawing groups to tetrahedral for low
electron withdrawing groups. Attempts to correlate
with toxicity; cf., polarizability (Safe's" earlier
work), geometry, and steric interactions; cf. PS51.
PS 51 — "Calculated Molecular Geometries and Energies
of All CDDs Using MMP2"
A "non-quanatum mechanical technique", involving
"forcefield calculatiohs", leads to estimates of
geometry. The COC bond angles are determined from IR
and correlated with toxicity; cf. PS48.

-14-

�s. PS55 -- "Thermal Decomposition Curves of HDDs by Scanned
Flow Tube Pyrolysis Method with On-line Ion Trap MS
Detection"
t. PS59 — "An Evaluation of the Molecular Structure of
OCDF" (and HpBrDF)
Planar. Low energy UV preferentially removes Cl at the
9 position. Higher energy UV is less selective.
Apparently OBrDF cannot be made due to steric
hindrance; you get decabromodiphenyloxide instead.
Further, only one HpBrDF forms (9 position vacant),
while four HpCDFs form,
u. PS68 -- "Receptor Binding Characteristics of 2378-CDF
Radioligands"
Kds: 2,3,7,8-TCDF = 1.3 nM
1,2,3,7,8-PeCDF= 5.9 nM
1,2,3,6,7,8-HxCDF= 2.3 nm
These values did not correlate with competitive
displacement of tritiated 2,3,7,8-TCDD of in vitro
AHH induction. Apparently the oral presentation
discussed the implication of these results.

-15-

�C. Dose-Response Assessment (Dose-Response, some Risk
Characterization, and selected posters dealing with
TEFs)

1 . Direct Potency
a. D R 0 1 — "Reexamination of the D-R Relationship for
Induction of the Hepatic Monooxygenase System by
2,3,7,8-TCDD"
Looked at enzyme induction at near lethal doses. An
unanticipated "super induction" is seen.
b. RC08 — "Cancer Risk Characterization of HxCDD"
The GAG potency calculation. Reference to a Moolgavkar
model result that is two orders of magnitude lower.
c. PS42 -- "Quantitative Model for the Tumor Promoting
Activity of 2,3,7,8-TCDD"
The application of Moolgavkar to 2,3,7,8-TCDD gives
results that are two orders of magnitude lower than
the UCL of the LMS. "More than half of this
difference can be attributed to the differences
between the higher background female rat liver tumor
and lower human liver cancer rates. The second major
factor is the difference between the MLE of the M-V-K
model vs the UCL used with the LMS."
2. TEF related data
a. DR02 -- "Effect of Pharmacodynamic Considerations on
TEFs for CDDs and CDFs"
Might want to consider changing values for
2,3,4,7,8-PeCDF, 1,3,4,7,8-PeCDF, and OCDD.
.b. DR03 -- "Applications of the In Vtiro AHH Induction
Bioassay for Determining TEQs: Pyrolyzed Flame
Retardant Mixtures"
Good correlation between in vitro AHH induction and in
vivo AHH and EROD induction, body weight loss and
thymic atrophy.
c. DR04 — "Subchronic Effect of Exposure to OCDD"
Linear absorption of small doses over time. Final
levels: liver, 222 ppt; adipose, 165 ppt; skin 160
ppt; and blood 70 ppt. (Cf. Rappe's Spaniard with
900,000 ppt OCDD in the blood.) Increased liver/body
wt, but no change in thymus. EROD and P-450 show
D-R. Analyzed both the chemical and the liver for
all CDDs/CDFs. Non-OCDD contaminant levels cannot
account for observations. TEF = .009. Commenters
noted that "classical dioxin-like activity" (e.g.,
thymus and body wt decrease) have not yet been seen.
Response: The response seen here is like that seen at
low doses of 2,3,7,8-TCDD. More work is underway.
d. PS11 — "TEFs for 2378-CDDs/CDFs by the E.L.S. Bioassay"
This is a fish fry assay, which has not yet been
generally accepted. However, the TEFs are as
follows:
2,3,4,7,8-PeCDF
= .4
1,2,3,7,8-PeCDF
= .04

-16-

�1,2,3,6,7,8-HxCDF = .04
PS43 -- "Validation of the AHH Induction Bioassay for
the Determination of TEQs"
Safe's work for CDDs, CDFs, and PCBs. Demonstrated
log-log linearity between in vitro AHH induction and
in vivo AHH induction, body wt loss and thymus
atrophy.
PS45 — "Relative Toxicity of CDDs and CDFs Measured by
Thymus Weight and Liver Enzyme Induction in
Perinatally Dose Rats: 2,3,7,8-TCDD, 2,3,4,7,8-PeCDF,
and 1,2,3,7,8-PeCDD"
TEFs
1,2,3,7,8-PeCDD
= .16
2,3,4,7,8-PeCDF
= .05 (Ed. note: Strange)
In utero exposure is about equal to exposure via milk.

-17-

�D. Exposure
1 . Analytical
These are found in the 32 papers of the Analytical
Methods section and several of the Poster papers.
There were too many to discuss here. Some were
somewhat arcane', but generally lead to lower
detection limits in various media. Others were
related to new methods, both instrumental and
biologically based.
2. Sources (MWCs) (Source Emissions, Levels/Trends, and
selected Posters)
a. SE09 -- "On the De Novo Synthesis of PCDD/PCDF on Fly
Ash of MWCs"
Baking "clean" fly ash, carbon and inorganic Cl at 300
degrees C for two hours apparently can give rise to
CDDs/CDFs in the ppb range; hence, "de novo"
synthesis. The presence of a little copper as a
catalyst is helpful.
b. SE10 -- "Joint German/Swedish Program on Testing
Sampling Equipment for MWC Incinerators"
c. SE11 — "Chemistry for Formation and Fate of PCDD/PCDF ,in MWC Process"
Only minor amounts of CDDs/CDFs in the fire box (650 700 degrees C). CDDs/CDFs formed on the way to the
heat exchanger (250 - 350 degrees), as well as
Cl-phenols formed. CDDs formed on fly ash. Amount
of CDDs/CDFs varies 10x depending on operating
conditions.
d. SE12 -- "Air Emission Characterization of a Two Stage
MWC"
Results of testing at one NY facility.
e. LT05 -- "CDDs/CDFs in Fly Ash from MWC"
Tests the hypothesis that (effectively) total TEQs can
be estimated from values for TCDD. Finds that
"...fly ash does not have a very useful
characteristic profile (fingerprint)."
f. LT06 -- "Complete Analysis of Organic Compounds in MWC
Flyash using HPLC and GC/MS"
Levels of CDDs/Fs from Machida incinerator (Japan) are
significantly lower than most other MWCs.
Insert a barrier in order to generate more turbulence.
g. PS50 — "Determination of PBrDDs and PBrDFs and Mixed
Br/Cl Ds/Fs in Environmental Samples"
Data have been obtained from MWCs and automobiles,
h. PS54 — "Theoretical and Experimental Analysis of the
Post-combustion Region of an Incinerator"
i. PS61 — "Evidence for Post-Furnace Formation of PCDDs
and PCDFs: Implications for Control"
Review of studies in the literature
'

3. Sources (Other Than MWCs)
a. S E 0 1 — "Emissions of PCDDs and PCDFs from the Swedish

-18-

�Pulp and Paper Industry"
Found it in the emissions from combustion of "black
liquor". (EPA's Tier 4 did not find any here.)
Found it in wastewater in low ppqd. The suspended
solids had it in the ppt range.
SE02 — "Occurrence and Fate of CDDs and CDFs in
Bleached Draft 'Papermaking Processes"
EPA's tale.
SE03 — "CDDs and CDFs in Effluents and Sludges from
Pulp and Paper Mills"
Comparable to EPA data.
SE04 — "Emissions of CDDs and CDFs in Gasoline and
Diesel Fueled Cars"
Actually looked for and found Cl, Br and mixed Cl/Br
dioxins and furans. Estimated total in Sweden is 3-7
g/yr, which is about 10% of the amount generated by
MWCs in that country. Most the TEQs are from TCDF.
SE05 — "Levels of Bioactive CDFs in Used and Unused PCB
Dielectric Fluids"
Concludes that "...normal usage of capacitors and
transformers does not result in the conversation
(sic!) of PCBs to PCDFs."
SE06 — "Environmental Behavior of
Monomehtyl-Substituted Polychlorinated
Diphenylmethanes (Me-PCDMs) in Comparison with PCBs"
These Me-PCDMs are PCBs substitutes in the electrical
and hydraulic situations. It appears that they have
similar problems, however. For example, pyrolysis
yields up to ppthousand levels of CDFs, and fish
bioaccumulation is likely to be similar to PCBs.
SE07 — "Search for Industrial Sources PCDDs/PCDFs: IV.
Phthalocyanine Dyes"
CDDs/CDFs in the ppt/ppb range. In general,
"...chlorobenzene with catalytic amounts of CuC12 or
the chlorophenols which are present in most
commercial chlorobenzenes cause the PCDD/PCDF
formation. Some experiments were made for prevention
of PCDD/PCDF formation."
SE08 — "Pyrolysis of Dibenzodioxin, Dibenzofuran and
1,2,3,4-TBrDD with Different Chlorine-donors and

Catalyts"
SE13 — "Ash Data from Combustion Sources"
EPA's Tier 4 results. Flyash levels of CDDs/CDFs are a
qualitative, not quantitative, indicator of CDD/CDF
stack emissions.
SE14 — "Production of CDDs and CDFs During the Thermal
Treatment of Soils Contaminated with
Hexachlorohexane"
CDDs are ND around 750 degrees C; CDFs ND about 1100.
SE15 -- "PBrDD and PBrCDF from Brominated Flame
Retardants"
The German study. Higher Br compounds photodegrade. A
.1 ppb detection limit is not realistic since the
brominated diphenyl ethers cannot be separated from

-19-

�the BrDDs, due to the lower solubility of BrDDs
1.
m.

n.

o.

p.

q.

compared to CDDs. This makes EPA's detection limit
of .1 ppb seem unrealistic.
SE16 — The American Study of the BrDDs/Fs from
retardants.
PS09 — "Tetrachlorobenzoquinones as Source of
PCDD/PCDF"
0-Chloranil and p-chloranil have levels of CDDs/CDFs in
the ppb range, up to ppm for OCDD/F.
PS27 -- "CDD/CDF and Chlorinated Phenols in Wood
Preservation Formulations for Household Use"
Levels are reported in PGP paints produced in the
1965-85 timeframe in Germany. In addition, levels in
dust from homes are also reported,
PS56 -- "CDDs and CDFs in the Environment as a Result of
Outdoor Chemical Waste Burning"
Uncontrolled burning of wastes, including 2,4,5-T still
bottoms.
PS57 -- "Emissions of PCDDs and PCDFs from the PVC Fire
in Holmsund, Sweden. A Case Report"
A January, 1987 plastic carpet company fire was
investigated. "Surprisingly low levels of dioxins
were detected" inside the building. Levels were
found in the snow downwind,
PS58 — "Monitoring New Source of PCDD and PCDF:
Automotive and Straw Firing"
Automotive data are compared with MWC. Straw is
regularly burned in Denmark to clear fields and for
residential and community heating. Straw contains
.1% Cl. Home firing exceeds Swedish MWC standard of
.1 ng TEQ/m3. Community firing is at .1 ng/m3 level.

4. Transport and Fate (Transport and Fate, Levels and Trends,
and selected posters)
a. TF01 — "Geometrical Description of the TCDD
Contamination in Times Beach"
Used the Univ of Pavia method for depicting the spatial
distribution of the surface contamination.
b. TF02 -- "Bioavailability of Grain and Soil Borne
Tritiated 2,3,7,8-TCDD Administered to Lactating
Holstein Cows"
Bioavailable equally from crushed grain and "aged"
soil. 50% is excreted in the feces, 40% stays in the
fat. 15% comes out in the milk, mostly within 4
days. No receptor found in cows. No adverse effects
are seen in 14 days.
c. TF03 — "PCDD and PCDF Bioaccumulation by Lake Ontario
Fish: Sediment to Fish Residue Relationships"
For slimy sculpins, the ratio ranged from 1:1 to 1:.1.
More data were presented and compared with
predictions.
d. TF04 — "Bioavailability of CDDs from Contaminated
Soils"
TCDD
HpCDD
OCDD
-20-

�e.

f.

g.

h.

i.

j.

k.

1.
m.

Newark:
1.6%
6.4%
2.6%
Times Beach:
30%
8.7%
3.6%
TF05 -- "Sorption of Dioxins to Soils"
Log Koc, normalized on fraction of organic content in
the soil, for some 2378-CDDs. There were more
hydrophobia than predicted.
'
Log Koc
2,3,7,8-TCDD
6.6
1 ,2,3,4,7,8-PeCDD
5.1
1 ,2,3,4,7,8-HxCDD
7.5
1 ,2,3,4,6,7,8-HpCDD
6.9
OCDD
7.9
TF06 — "Photolysis of OCDD on Soils: Production of
2,3,7,8-TCDDr'
In solution, the lateral Cls seem most likely to be
removed. On soil, the reverse is true and
2,3,7,8-TCDD is a sink. [This is similar to what the
Wizards observed some time ago.]
TF07 — "Measurement of the Photoinduced Loss of Vapor
Phase TCDD by MS"
Lab study suggests a half life of 11 min for 355 nm
high pressure light. Quantum yield of .02. [Use
this with the characteristics of the solar spectrum
to predict environmental half life.]
TF08 — "Long-Range Transport of PCDD, PCDF, Cl-PAH and
PCP on Airborne Particles"
Slight variation in congener (sic -- we would say
"homologues") profiles. Isomeric patterns within a
homologue are similar and are characteristic of auto
and MWC emissions.
TF09 — "Studies of Physico-Chemical Parameters
Affecting Translocation of PCDDs in Soil"
Mobility highest in the presence of organic solvents,
but not directly related to solubility. Examines
effects of surface area, pore size distribution,
organic matter content, type of soil organics and the
potential for micelle formation.
TF10 -- "Field and Lab Studies on the Movement and Fate
of TCDDs in Soil"
Simulates the conditions at Times Beach. "The results
obtained indicate that both the migration and loss of
TCDD from soil through such processes as
volatilization and subsequent photolytic degradations
or through direct surface photolysis of soil-bound
TCDD are substantially lower than the values
previously reported in the literature."
TF11 — "Comparison of the Rate of TCDD Transport at
Times Beach and at Eglin AFB"
Freeman and Schroy revise approach to fit Yanders1
data.
TF12 and PS02-- "Estimating Exposure to 2,3,7,8-TCDD"
EPA's "Fat Document"
LT15 -- "Human Exposure to 2,3,7,8-TCDD"
ORNL global modelling of 2,3,7,8-TCDD, leading to an

-21-

�estimated intake of about 1 pg/kg-d, 98% of which
comes from food, especially meat and dairy products,
not contaminated fish and shellfish.
5. Environmental Levels (Levels and Trends and selected
posters)
a. LT01 -- "PCDD/PCDF' in Dutch Inland Waters"
Investigation of waste water discharges, sediments and
fish. Sediments had differing profiles. "..[i]n
only a few cases could (the profiles) be related to
the sources."
b. LT02 — "CDDs/CDFs in Selected Estuarine Sediments"
Samples from New Bedford Harbor, Bridgeport and upper
Narragansett Bay. PCDFs decreased with distance less
rapidly in NBH than did the PCBs. [Additional
sources? Differential decomposition?]
c. LT03 -- Plant Surfaces: A Sampling System for
Atmospheric PCDDs and PCDFs
"Since uptake PCDDs and PCDFs via roots can be
excluded..." [Basis?] Hutzinger's work on pine
needles: ppt levels of all CDDs/Fs. Profiles typical
of combustion sources.
[How does this correlate with
Crosby's finding of short half life on leaves?]
d. LT04 — "Surface Contamination of PCDD and PCDFs in PCS
Disposal Facility"
Three facilities examined for air and surface levels of
PCBs, employee blood levels for PCBs, and surface
levels of CDDs/CDFs.
e. LT07 -- "PCDDs and PCDFs in the Dust of the Working
Atmosphere of a MWC"
The dust is "quite different from the flyash samples
usually collected in incinerators." All of the
CDDs/CDFs are present. 2,3,7,8-TCDD was found a
about .9 ppb and 6 pg/m3.
f. LT08 — "Ambient Air and Incinerator Testing for
CDDs/CDFs by LR-MS"
Kites showed 1 pg/m3 per congener group or lower in
ambient air around Bloomington, IN. This study also
shows about 1-2 pg/m3 for the most abundant congener
groups. "TCDFs predominate in some samples, while
OCDD predominates in others."
g. LT09 — "CDDs/CDFs in the Ambient Atmosphere: A Baseline
Study"
Bloomington, IN data of Kites
Vapor
Particle
Vapor
Part.
TCDDS
20 fg/m3
ND
TCDFs
350
20
PeCDDs
50
25 fg/m3 PeCDFs
65
35
HxCDDs
20
120
HxCDFs
20
75
HpCDDs
25
280
HpCDFs
6
100
OCDD
150
750
OCDF
9
40
h. LT10 — "Background Concentrations of CDDs and CDFs in
Commercial Office Buildings"
Two "clean" buildings in Boston and three in Santa Fe.
2,3,7,8-TCDF found in 36/41 of wipe samples; only in
-22-

�i.

j.

k.

1.

m.

n.
o.
p.

q.
r.

s.

4/28 air samples. 2,3,7,8-TCDD was ND (100 pg/m2 and
1 pg/m3). Predominant presence of OCDD and OCDF.
Compared to levels in PCB-fire buildings,
LT11 -- "Pattern Analysis of PCDDs and PCDFs in
Environmental Samples as an Approach to a
Source/Occurrence Correlation"
Looks at homologu'e profiles, D/F homologue ratios,
isomer patterns, 2378-patterns. [This might be
helpful.]
LT12 — "PCDD and PCDF in Indoor Air of Kindergartens in
N. FRG"
Examines indoor and outdoor air of facilities treated
with PCP or Lindane. Levels in wood also presented.
TEQs generated.
See RM02.
LT13 -- "CDD/CDF Levels in Food Samples Collected in
1984-87 in N and S Vietnam"
Data from pork, duck, beef, chicken, turtles, fish and
snakes.
LT16 — "Environmental Levels of CDDs and CDFs"
General survey by Rappe. Sediments reflect long range
airborne transport and local sources. Baltic Sea
fish are about the same as 15-20 years ago. Levels
of TCDF are found in deep (150 cm) sediment. This
may be due to formation 300 years ago, or it may be
due to some sort of "leaching" into the sediment. '
PS04 -- "PCDD and PCDF in Mice and Insects from Various
Environments"
Levels in insects are similar to the soil. Levels in
mice (including skin), excised of the liver, are
similar to soil. Liver is not like the soil.
"...[H]erbivoran mice showed PCDD/PCDF levels much
lower than carnivoran mice."
PS05 -- "Survey of Background Levels of PCDDs and PCDFs
in UK Soil"
100 points of a 50 km grid. No data in the abstract,
PS06 -- "CDD and CDF Levels from Soil Collected in
1984-86 in N and S Vietnam"
An advertisement, not an abstract,
PS07 -- "Monitoring Ds/Fs in Precipitation Samples"
Samples obtained from a remote area. TCDD and TCDF are
ND at 4-30 ppqd. OCDD was found 120-620 ppqd. Lower
levels of HpCDD and HpCDF.
PS24 -- "Analysis of Fog Samples for PCDD and PCDF"
OCDD predominates, although HpCDD is the only other CDD
present. T- thru OCDF found at lower levels,
PS25 -- "Concentrations of PCDD and PCDF in Soil from
Vicinity of a Large Refuse Incinerator in'Hamilton,
Ontario"
Lack of correlation between predicted locations of high
CDD/F levels and analytical results. And this at one
of the highest "dirtiest" emitters. Hmmm.
PS26 — "Mathematical Approach to the Data Analysis in
Environmental Science. The Lecture Learnt from
Seveso"

-23-

�A critique of past reports,
t. PS49 — "Recoveries of the Early Analytical Procedures
to Detect 2,3,7,8-TCDD in Soil Samples in Seveso"
Makes the point that maps drawn before 1979 "...were
characterized by underestimation, sometimes
remarkable, of TCDD levels -- especially where
contamination was higher."
u. PS56 — "PCDD and PCDFs in the Environment as a Result
of Outdoor Chemical Waste Burning"
Top soil concentrations of 2,3,7,8-TCDD up to 50 ppb.
Total of 159 ppt TEQs. Sediments at nearby shoreline
showed Pe- thru 0- CDD/CDFs; no detectable
2,3,7,8-TCDD. Eel had only 82 ppb HpCDD; no other
CDDs/CDFs. Rabbit livers had up to 500 ppt TEQs;
2,3,4,7,8-PeCDF accounting for 90% of the TEQs.
v. PS64 — "Planar and Coplanar Polychloroaromatic
Compounds in Baltic Salmon and White-Tailed Eagle"
PCBs, DDTs, and Chlordane present in the ppm range.
Some PCDDs/PCDFs seen near 1000 ppt.
w. PS65 — "Survey of 2,3,7,8-TCDD in Selected Plants and
Animals from Times Beach"
Advertisement, not an abstract. [Should be
interesting, though.]
6. Human Tissue Levels
There were 24 papers and 6 posters (PS-31, -46, -47, -53,
-62, and -63) addressing this subject. Basically,
they re-enforced previous information; e.g.,
background levels in fat and blood, half life values,
industrial vs. non-industrial nations, 1 pg/kg-d
intake, and higher levels in occupationally exposed
folks.
Consult abstracts for details and some more interesting
information (which is not to imply that this
information is "uninteresting"!).

-24-

�E. Risk Characterization (Risk Characterization section)
Risk characterizations were presented for
Human milk (RC02 - WHO)
Occupational setting (RC04 - Paustenbach)
Land application of paper mill sludge (RC07 - Envirologic
Data).
Other papers raised questions about and pointed to the need
for improvements in the exposure assessment of any RC:
RC01 - need for greater attention to dealing with
uncertainty
RC05 - need to reassess exposure due to application to
agricultural soils
RC06 - need for validation of air dispersion modeling.
Commenters noted that consumption of fish should yield 40
ppt in fat of people. Generally this is not seen.
However, see paper by CA DOH: HT11.
F. Control Options (Control Technology section and selected
posters)
MWCs, landfills, photochem, etc. treated.
G. Risk Management (Risk Management section)
Abstracts are self-explanatory.
Particularly noteworthy is
RM02 — "indoor Air Pollution by Dioxins in Day-Nurseriesr;
RA and RM". Cf. LT16.

-25-

�III. Scuttlebutt
A. SOme researchers are examining coffee (thru paper filter)
and tea (thru paper bag) for the presence of 2,3,7,8-TCDD
and 2,3,7,8-TCDF.
B. The materials associated with the briefing of the Ad Hoc
"Dioxin" Group to the Administrator on the "window" of
2,3,7,8-TCDD toxici'ty was released to EOF as a part of
the discovery action related to the EDF-EPA law suit.
C. In Sweden, these sources are approximately equal
contributors of CDDs/Fs into the environment:
MWCs, automobiles, steel plants, and pulp and paper plants
D. The CDC 1 ppb risk assessment assumed that a cow would
ingest up to 2 kg of soil while grazing. This is an
outer limit. A more realistic number would be .3 kg.
(There is a question, however, as to whether the grass
itself would have CDDs/Fs in/on the blades.)
E. I understand that concerns originally raised by the
Battelle report on the collection efficiency of the EPA
air sampler has been resolved; cf. Haggenmeir.
Therefore, the Tier 4 data are probably firm. (We had
thought that they might be as much as 10x too low.)
F. At the Univ of NV at Las Vegas 90% of the students are from
in-state. (All but the basketball team?!) The
University will give a 4-year "free ride" to the
valedictorian of any NV high school.
G. There were more than 500 participants from 18 countries.
Next year the conference will be in Sweden. The bidding
has already begun for the following year. More people
are questioning the need for an annual conclave.
H.-A1 Young didn't make it this year.
I. The Wizards may be able to help unravel the Battelle
report.
J. 2,3,7,8-TCDD volatilizes off glass at 40 degrees C.
K. Harless is getting a new instrument, which will put him
back into the hunt.
L. Not everyone agrees with Greenpeace's assessment of Barnes!
M. NTP is testing phorbol esters for carcinogenicity. The
result could shed light on the question of TCDD's
promoter/initiator status.
N. NTP is conducting skin promotion studies with PeCDFs.
0. The proposed TEFs for the NATO CCMS are as follows:
2,3,7,8-TCDD 1
2,3,7,8-TCDF .1
2378-PeCDF
.5
2,3,4,7,8PeCDF .5
Other 2378-PeCDFs .01
2378-HxCDD
.1
2378-HxCDFs .1
2378-HpCDD
.01
2378-HpCDF
.01
OCDD
001 or .0001
OCDF
.001 Ot .0001
All non-2378-TCDDs are ignored since they do not show up in
biological tissue and their collective impact is small in
the current scheme. The guiding principal of this
proposal is simplicity.

-26-

�IV. Personal Activities
1. Presented plenary lecture on Risk Characterization. Paper
is to be published.
2. Participated in a press conference with Eric Bretthauer,
Gary Amendola, Alec McBride, Chris Rappe, and Ray
Clement.
3. Participated in a conference call on levels in residue from
incineration of 2,4,5-T and Silvex. I am on the point
for discussing the model, which I strongly suspect as^not
being applicable in this case. Consider total
2,3,7,8-TCDD and the impact of local dispersion in the
environment.

4. Chaired the session on Dose-Response Assessment.
5. With Judy Bellin, co-authored a paper on TEFs with Jim
Olson of SONY. Jim is the lead author and will prepare
it for publication.
6. Chaired the session on Risk Characterization.
7. Presented final plenary lecture on Risk Characterization.
Summary to be published.
8. Chaired a rump session of the NATO CCMS group addressing
TEFs which led to a proposed "common set of TEFs" for
consideration by member countries. I have to prepare
this for more formal circulation to all participants and
eventual publication.
9. I introduced myself to two young women from Greenpeace. We
had a pleasant discussion about regulatory actions and—
inactions regarding ./dioxin". I asked them to send me
their views on the/biggest dioxin problems facing us and
their recommendations for action.
10. I met a woman from Ohio who is concerned about land
application o^r 2,3,7,8-containing sludge to old
stripmined Lands. We have chatted on the phone a few
times in t)*e past. She had become aware of my recent
notoriety/ I put her in touch with folks from EOF and
Greenpeace, as well as discussing some of her concerns
with h«

/p,- / ^
fv,

r\&amp;fitf.l-t-

-27-

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