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Summary of Review Panel
Meeting
Review Panel (Roles and Expertise): Michael L. Dourson (Review Panel Chairperson,
General Risk Assessment and Toxicology) Linda Erdreich (Risk Assessment and
Epidemiology) Harvey Clewell (Risk Assessment, Biostatistics,
and Modeling) Meeting Notes and Summary: Kenneth A. Poirier Representing Health Canada, Priority Substances Section, Environmental Substances Division, Environmental Health Directorate, Health Protection Branch, Tunneys Pasture, Ottawa, Ontario, K1A 0L2: Bette Meek (Section Head) Other Public Attendees: Mark Korchinski Site of meeting: Lord Elgin Hotel Background Purpose of the Assessment: The information presented in this section was taken from the background documentation provided to the review panel. The Canadian Environmental Protection Act (CEPA) requires the federal Ministers of the Environment and of Health to prepare and publish a Priority Substances List that identifies substances, including chemicals, groups of chemicals, effluents and wastes that may be harmful to the environment or constitute a danger to human health. The Act also requires both Ministers to assess these substances and determine whether they are "toxic" as defined in Section 11 of the Act, which states:
Based on initial screening of readily accessible information, the rationale for assessing 1,3-butadiene (hereafter referred to as butadiene) provided by the Ministers Expert Advisory Panel on the Second Priority Substances List (Ministers Expert Advisory Panel 1995) was as follows:
Supporting documentation and the content of the health-related sections of the summary assessment report were prepared by K. Hughes, M.E. Meek, D. Moir and M. Walker of Health Canada, based, in part, on background information prepared (1994) by BIBRA Toxicology International: Sections of the Supporting Documentation on genotoxicity and reproductive and developmental toxicity were reviewed by D. Blakey and W. Foster, respectively, of the Environmental Health Directorate of Health Canada. A review of the exposure assessment included in the critical epidemiological studies was prepared under contract by M. Gerin and J. Siemiatycki of the Institut Armand-Frappier. In the first stage of external review, background sections of the Supporting Documentation pertaining to human health were reviewed and written comments were provided by the following 10 individuals primarily to address adequacy of coverage (December, 1997). The principal criterion for selection was likely familiarity with recent, relevant data in critical areas including toxicity (particularly genetic toxicity), epidemiology and metabolism. Names, affiliations and relevant areas of expertise of first stage reviewers were as follows: J. Aquavella, Epidemiologist, Monsanto Company M. Bird, Toxicologist, Exxon Biomedical Sciences, Inc. J.A. Bond, Researcher, kinetics and metabolism,
development of PBPK model on butadiene, Chemical Industry I. Brooke, Toxicologist, Principal evaluator
for UK assessment and rapporteur for the EU assessment on
butadiene, G. Granville, Toxicologist, Shell Canada Ltd. R. Keefe, Toxicologist, Imperial Oil Ltd. A. Koppikar, Epidemiologist, Principal
evaluator for U.S. EPA assessment of butadiene, U.S.
Environmental R.J. Lewis, Toxicologist, Exxon Biomedical Sciences Inc. K. Peltonen, Researcher, kinetics and
metabolism, Investigated formation of adducts with butadiene and
metabolites F. Ratpan, Genetic toxicologist, Nova Chemicals In a subsequent stage of external peer review, a second draft of the Supporting Documentation, which incorporated comments from the first stage review in addition to the first draft of the sections on Hazard Characterization and Dose-Response Analyses, was forwarded for written review to 23 individuals and groups (March, 1998). The charge to these reviewers was to address specifically the adequacy of coverage and accuracy of reporting and defensibility of conclusions with respect to hazard characterization and dose-response analyses. These reviewers were selected to broadly reflect the range of scientific views of the research community addressing butadiene in critical areas including metabolism, genetic toxicity, epidemiological study and dose-response analyses, the latter particularly for that based on epidemiological data. Additional reviewers in each of these areas were selected who were not involved in research on butadiene, per se, but rather offered experience relevant to a more distanced assimilation of the data for purposes of development of the Hazard Characterization and Dose-Response analyses. Responses were obtained from all but one reviewer (E. Frome). Second stage reviewers were as follows: R.J. Albertini, Genetic toxicologist, Principal investigator of transitional epidemiological study on biomarkers for butadiene, University of Vermont, Information Department, BIBRA International, U.K. J. Bucher, Deputy Director, Environmental Toxicology Program, U.S. National Toxicology Program B. Davis, Head, Ovarian Toxicity/Carcinogenicity Group, Environmental Toxicology Program, U.S. National Toxicology Program E. Delzell, Epidemiologist, Principal author of critical epidemiological study of styrene-butadiene rubber workers, University of Alabama at Birmingham B.J. Divine, Epidemiologist, Principal author of key epidemiological study of butadiene monomer workers, Texaco A.A. Elfarra, Researcher, kinetics and metabolism on butadiene, University of Wisconsin-Madison E. Frome, Senior statistician, Oakridge National Laboratory B.D. Goldstein, Academic researcher, Environmental and Occupational Health Sciences Institute, New Jersey R.F. Henderson, Researcher, kinetics and metabolism on butadiene, Lovelace Respiratory Research Institute R.D. Irons, Researcher, mechanism of action of lymphohematopoietic carcinogens, University of Colorado Health Sciences Center J. Lubin, Senior statistician, National Cancer Institute J. Lynch, Consulting industrial hygienist, Directly involved in developing the exposure estimates for the critical study of styrene-butadiene rubber workers and transitional epidemiology study on butadiene biomarkers, Exxon Biomedical Sciences, Inc. (retired), R.L. Melnick, Toxicologist, Toxicokinetic modeling, Principal investigator in critical cancer bioassay in animals; U.S. National Toxicology Program A.G. Renwick, Researcher, kinetics and metabolism, University of Southampton J. Siemiatycki, Epidemiologist, Institut Armand-Frappier L.T. Stayner, Epidemiologist/biostatistician, Supervised and participated in quantitative analyses of the critical epidemiological study in butadiene rubber workers for dose-response for the U.S. EPA assessment, U.S. National Institute for Occupational Safety and Health J.A. Swenberg, Researcher - DNA adducts in workers exposed to butadiene, University of North Carolina R. Tice, Genetic toxicologist, Integrated Laboratory Systems, Inc. J. B. Ward Jr., Genetic toxicologist, Researcher on genetic effects in workers exposed to butadiene, University of Texas Medical Branch The revised documentation was also forwarded to several of the same individuals who provided review in stage 1, primarily to access their input with respect to defensibility of conclusions in the Hazard Characterization and Dose-Response Analyses (additional comments were not received from two of these individuals). These reviewers included:
Charge to Reviewers of the Technical Oversight Panel of November 30, 1998: The reviewers were requested to review the critical evaluation from each external reviewer and evaluate the disposition of comments by Health Canada, with particular attention to their areas of expertise. The reviewers were requested to review the critical evaluations from each external reviewer and evaluate the disposition of comments by Health Canada. In addition they were charged with paying particular attention to their area of expertise. As part of the summary of external peer review comments and issues, Health Canada developed and iterated a number of key points for consideration by the review panel. The panel was asked to provide comment on other issues that were relevant to the adequacy of the incorporation of the comments of the peer reviewers. The issues (1-12) stated below are verbatim as presented to the review panel by Health Canada. The paragraph, which follows the identified issue, is a synopsis of the review panels discussion. Review Panel Comments on the Identified Principal Issues:
Additional references were recommended for
inclusion by several of the external reviewers. The panel
reviewed the updates made to the risk assessment with Health
Canada. Some references were not included if they did not enhance
the discussion or had been previously cited in other sections of
the document. For example, Melnick, recommended that four
references be added. Two were and two were not because the latter
were secondary reviews of primary reports from the literature,
which had already been cited in the assessment. Clewell commented
favorably on Health Canadas ability to resolve the issues
and in particular the consideration given to the expert
reviewers recommendations. Dourson, on behalf of the
assembled review panel, declared that Health Canada had
considered and addressed the reviewers comments
appropriately and adequately addressed issue 1.
Clewell responded that the documentation as it
relates to clarification of the methodology used in the report
had been improved from the version originally submitted to the
expert reviewers even though the documentation was adequate in
the first draft. Still there is a need to adopt appropriate
nomenclature throughout the document to clearly distinguish
between estimates of exposure for humans and animals. In
particular, a standard nomenclature should be used to distinguish
animal NOAELs and BMCs from the human equivalent calculated
concentrations. Health Canada replied that a number of different
analyses were performed and they all yielded similar results. The
details of the analyses utilized are included in the revised
document. Clewell offered an opinion that the modeling still
needs to be more fully documented. In fact the results would
appear to be counterintuitive the models are different in
the range of the data, yet the results (TC.05) are
similar. Health Canada agreed to incorporate the suggested
changes. The panel agreed that Health Canada had addressed the
comments to the extent possible.
The panel agreed that Health Canada had addressed this issue by a footnote to the appropriate table. Clewell further noted that the mouse lymphoma data were appropriately addressed and that Health Canada had handled the endpoints quite well both in the table and in the text. The issue was determined by the panel to be appropriately addressed.
Erdreich pointed out that the weight of evidence for causality is a complicated issue and that the evidence for causality is always a problem when using epidemiological data. For example, questions can always be asked such as: What is the statistical criteria? How are the differences determined? Can one separate biological plausibility when assessing causality, especially in a risk assessment? For example, one must emphasize the precision of the estimate and separate that from the statistical significance. The process for assessing the weight of epidemiological evidence for causality is conceptually no different from the overall weight of evidence process. The standard guidance for assessing epidemiological data to reach a public health decision includes biological plausibility, often considered separately from the conclusion based on the epidemiological evidence. Health Canadas procedure to assess all available evidence, without presenting a specific conclusion based on epidemiological data, is certainly appropriate. Health Canada stated that there was a difficulty in reconciling opinions. Erdreich in turn indicated that the lymphoma/leukemia issue was handled very well by Health Canada in the text. There are many difficult issues surrounding the leukemia problem with butadiene, but certainly the weight of evidence, although not strong, exists for leukemia. The epidemiological data is not complete and the document explains this very well. However, Erdreich thought that it is important for Health Canada to also address the issue about the bone marrow stem cells and their relation to the origin of lymphoma/leukemia. The Panel recognized that the range of opinions expressed by the reviewers in this difficult and complex area, but felt that Health Canada had expressed the problem quite well. This is further illustrated by the fact that the weight of evidence of the available data, including the issue of coherence due to the lack of consistency of observed cancers between the monomer and rubber workers, is handled well in the text. Clewell added that there were a variety of opinions presented by the expert reviewers, which made it difficult to totally resolve the inconsistencies associated with the opinions expressed. Overall, the document finds the middle ground and expresses the problems quite well. Erdreich suggested that the data be additionally addressed in the uncertainty section. However, a good job was done with a difficult array of data. Erdreich also stated that she will provide editorial comment to this section to make it more understandable to the first time reader. Dourson emphasized that Health Canada used both the epidemiological and animal toxicity data in their conclusions to this section, a point that should not be lost on the readers. The review panel was satisfied with the way in which Health Canada approached this difficult issue.
Clewell stated that it was heartening to see
that the comments and suggestions of the reviewer had been acted
upon by Health Canada and this consequently had made for a
stronger document. Clewell also pointed out that the NTP endorses
the Poly-3 approach as a preferred method. The review panel
agreed with the changes made to the document.
Dourson asked whether TC.05 meant a 5% increase over the control level (i.e., 5% over 1.26 micronuclei per 100 cells or excess risk normalized by background rate). If so, what does this mean biologically. Otherwise, the modeling of micronuclei seemed appropriate and the description given by Health Canada was reasonable. Dourson also indicated that Figure 5 should state that the BMCs are in units of mg/m3, so as not to be confused with the dose scale in ppm. Clewell suggested that the observation of increased micronuclei is an interesting fact, but that the modeling does not provide any additional information to enhance the risk assessment. Therefore, it should have a supportive role and be mentioned in the text where appropriate. Health Canada agreed that the modeling did not lead to any meaningful risk assessment statement and there is not a good biological reason for doing multiple modeling exercises. Dourson thought that the response by Health Canada to the issues of modeling of the dose-response relationship for male mediated reproductive effects seemed appropriate. This was based on the description of these effects (found on text pages 9 and 10). Dourson suggested that acquisition of the historical control data of Anderson et al. (1993) and Brinkworth et al. (1998) might be informative to see if the effects 12.5 ppm are related to butadiene exposure or are more likely due to background. The Review Panel agreed that no further work should be attempted here under the scope of this particular document.
The Panel considered the data an unequivocal effect. Dourson pointed out that Table 15 clearly shows an increasing trend in both the incidence and severity of ovarian lesions. Whether this is due to a direct toxicity effect on the organ, or perhaps indirectly by way of an overall oxidation of the organism, is not particularly important. Making the animal (or its organs) prematurely senile is considered an adverse event. Dourson suggested that additional analyses of these data would make an interesting project (but not necessarily by Health Canada). He also suggested that instead of a BMD analysis, a categorical regression approach for these data would be more appropriate since there is a qualitative and quantitative progression of the effect. Clewell also pointed out that Health Canada was using a BMD approach, which would obscure trends such as changes in severity. For the purposes of the document, human cancer is the critical effect. No other development of the reproductive data needs to be undertaken. The Review Panel deemed the approach to comments taken by Health Canada to be appropriate. No further action is warranted by Health Canada.
Dourson asked Health Canada to more fully explain what was done to address this issue. Health Canada replied that literature searches were undertaken, but that no evidence was found in the literature to indicate that dimethyldithio- carbamate was carcinogenic. A statement to that effect was included in the document. Health Canada will also provide a review of the work and search strategy performed on the literature for the carcinogenicity of dimethyldithiocarbamate in the Appendix of the final version of the Assessment Report. The Review Panel did not request any additional work on this issue and felt it was adequately handled in light of the conflicting suggestions of previous reviewers.
The Panel commented that the text had been improved considerably since the first draft by the addition of the qualification. Erdreich thought that the current version of the document had revisited and adequately addressed these issues but noted that the version of the document sent to the expert reviewers did not adequately present the tire manufacturing data which should be considered non-informative regarding 1,3-butadiene. However, she also stated that there is no quantifiable exposure data available which may affect the confidence of the risk assessment. The Review Panel did not have any other comments and the issue was determined to be adequately addressed.
Erdreich replied that it is misleading to label entire studies as positive or negative, rather, the magnitude of the association (odd ratio or SMR) as well as the precision of the estimate (confidence interval) should be considered. To assess consistency, the trends and patterns in the data need to be considered. The tables in the document that were added in the most recent version of the risk assessment demonstrate the precision of the estimate and the points raised were handled well. The Review Panel agreed with the comments of Erdreich and no further action by Health Canada is required.
The panel stated that the document provided
ample discussion on the exposure issues. In addition, the panel
stated that this discussion of the data is important to the
document and that the exposure issues were addressed
appropriately. The issue was handled in the best way possible and
no further action by Health Canada is required. Clewell responded that when using epidemiological data, one needs to break out from convention, i.e., does the 5% incidence level relate appropriately to the incidence in the epidemiological studies. Clewell pointed out that it was actually necessary to extrapolate upwards from the epidemiological data to obtain a TC.05. An additional risk level closer to the range of the epidemiological data should also be calculated and presented, e.g., the TC.005, in order to better characterize risk exposures of environmental relevance. It was also suggested that the data on ovarian lesions be analyzed by categorical regression even though the quantitative dose-response analysis for cancer would likely drive the risk characterization and was therefore not considered critical for this assessment. The panel was not sure why the TC.05 effect level was selected. Health Canada replied that the TC.05 was developed by biostatisticians to compare with other tumor data. In Canada, both cancer and non-cancer effects may be used to develop an effect level. Clewell further expounded upon the cross-species scaling of butadiene. Health Canada had applied a cross-species dosimetry adjustment for both the cancer and non-cancer risk assessments for butadiene. The dosimetric adjustment assumes that the chemical in question is highly water soluble and is rapidly metabolized such that there is no re-entry of the chemical in venous blood into the lung. Butadiene is relatively insoluble in water and is relatively slowly metabolized and thus does not meet the assumptions of the dosimetric adjustment. Thus, according to the Us EPAs methodology, a default cross-species dosimetry of 1 is used. Use of this default ratio is estimated to be conservative by a factor of 2. Clewell therefore recommended that the adjustment for a ventilation to body weight ratio for butadiene not be constructed and utilized in this assessment. The panel was comfortable with the discussion of the dose response estimates in the document. The significance of the ovarian effects needs further exploration. However, it is not necessary for this document at this time and any work performed on the severity and/or incidence of ovarian tumors needs to be undertaken as a separate task and not necessarily by Health Canada. Review of Individual Expert Reviewer Comments: Dourson polled each of the Review Panel members for each Expert Reviewer comment(s) to insure that the individual issues raised were appropriately addressed. The panel commented on the breadth and detail of each review that the Expert Reviewers provided. In all cases the panel felt that issues raised by the expert reviewers were in most cases appropriately handled in the body of the document. (The few exceptions are mentioned above in the individual issue discussions). For those issues that did not result in changes or additions to the document, the Review Panel agreed with the rationale used by Health Canada to not amend the document. The Panel suggested that the discussion of likely heterogeneity in the human population due to complexity of metabolic pathways be emphasized less and also suggested that the terminology used in the dose-response analyses with respect to unadjusted and human equivalent doses be clarified and standardized throughout. Finally, the Review Panel also agreed with the disposition of comments by Health Canada on the Health Risk Assessment for 1,3-Butadiene. © 2003 Toxicology Excellence for Risk Assessment 2300 Montana Avenue, Suite 409,
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