Safety assessment procedures for indirect food additives: an overview. Report of a workshop

Application of the threshold of toxicological concern (TTC) to the safety evaluation of cosmetic ingredients

The threshold of toxicological concern (TTC) has been used for the safety assessment of packaging migrants and flavouring agents that occur in food. The approach compares the estimated oral intake with a TTC value derived from chronic oral toxicity data for structurally-related compounds. Application of the TTC approach to cosmetic ingredients and impurities requires consideration of whether route-dependent differences in first-pass metabolism could affect the applicability of TTC values derived from oral data to the topical route. The physicochemical characteristics of the chemical and the pattern of cosmetic use would affect the long-term average internal dose that is compared with the relevant TTC value. Analysis has shown that the oral TTC values are valid for topical exposures and that the relationship between the external topical dose and the internal dose can be taken into account by conservative default adjustment factors. The TTC approach relates to systemic effects, and use of the proposed procedure would not provide an assessment of any local effects at the site of application. Overall the TTC approach provides a useful additional tool for the safety evaluation of cosmetic ingredients and impurities of known chemical structure in the absence of chemical-specific toxicology data.

An impact analysis of the application of the threshold of toxicological concern concept to pharmaceuticals

The recent application of the threshold of toxicological concern (TTC) concept to the regulation of pharmaceuticals in the European Union is analyzed. The derivation of TTC and the threshold of regulation that followed it were originally intended to provide makers of food contact materials greater flexibility with their products, while allowing the CFSAN branch of FDA to conserve its resources for more important issues. A reanalysis of the scientific data employed by EMEA regulators to rationalize its 1.5 mcg default genotoxic impurity limit is presented to demonstrate (a) that direct translation of conclusions relevant to food consumption are unduly influenced by many classes of potent carcinogens of historic concern which would be impossible to generate unknowingly as pharmaceutical impurities, and (b) that the majority of reactive chemicals that would be useful to synthetic chemists are among the least potent carcinogens in the underpinning supportive analyses. Evidence is further presented to show that implementation and acceptance of a 1.5 mcg TTC-based total limit on such impurities can be expected to impede pharmaceutical research and development efficiency while providing an insignificant cancer risk-avoidance benefit to patients who require pharmaceutical treatments. The conclusion drawn is that a significantly higher default limit can readily be defended that would be both in keeping with TTC principles and the best interest of patients.

The concentration of no toxicological concern (CoNTC): a risk assessment screening tool for air toxics

Although numerous chemicals might occur in ambient air as a result of natural or anthropogenic activity (primarily through vehicle exhaust and industrial emissions), not all are necessarily of concern for public health even if they are classified as hazardous. There are many minor components in emissions that are predicted to be present at small concentrations. For the majority of these chemicals a health-based guideline does not exist to facilitate risk assessment. Furthermore, there are no appropriate toxicological or health data to enable health-based guidelines to be established. Consequently in most risk assessments these substances are usually, and conveniently, ignored. The tacit justification is that concentrations in ambient air are small and thus insignificant. For many stakeholders this is an inadequate explanation, and the justifiable question of how it is known exposures are insignificant for health is often asked. The concept of a "concentration of no toxicological concern" (CoNTC) was developed for air toxics and can be applied as a risk assessment screening tool to legitimately dismiss substances whose ground-level concentrations are predicted to be trivial. The CoNTC helps define trivial and is grounded in regulatory and scientific deliberations of the U.S. Food and Drug Administration (FDA) and the European Commission for developing concentrations of no toxicological or regulatory concern for contaminants in food. The suggested conservative generic CoNTC value that can be applied to most organic chemicals in air is 0.03 microg/m3. The derivation of the CoNTC and its validation and limitations are discussed, and its utility as a screening tool is presented.

Probabilistic ecological hazard assessment: evaluating pharmaceutical effects on aquatic higher plants as an example

The practicality of a probabilistic ecological hazard assessment (PEHA) methodology using intraspecies endpoint sensitivity distributions (IESDs) and chemical toxicity distributions (CTDs) was evaluated on data sets of pharmaceutical toxicity to aquatic macrophytes. A PEHA does not use an exposure distribution but rather uses a point estimate, which is useful for applications with sufficient effects data but lacking in comprehensive exposure data or when a criterion concentration is desired. The probability of finding an effect measure or potency value below a threshold can be calculated from the effects distribution. PEHA analyses using CTDs for both EC(10) and EC(25)Lemna gibba toxicity values indicated a <1% probability of encountering an antibiotic with toxicity below 1 microg/L. IESDs for microcosm mixture studies with eight pharmaceuticals (8PM) and four tetracyclines showed that the probability was nearly 20% for Myriophyllum sibiricum and 13% for L. gibba (8PM data). Hazard quotients calculated from the 1% and 5% distribution thresholds indicated potential risk only in certain cases.

Application of the threshold of toxicological concern concept to pharmaceutical manufacturing operations

A scientific rationale is provided for estimating acceptable daily intake values (ADIs) for compounds with limited or no toxicity information to support pharmaceutical manufacturing operations. These ADIs are based on application of the "thresholds of toxicological concern" (TTC) principle, in which levels of human exposure are estimated that pose no appreciable risk to human health. The same concept has been used by the US Food and Drug Administration (FDA) to establish "thresholds of regulation" for indirect food additives and adopted by the Joint FAO/WHO Expert Committee on Food Additives for flavoring substances. In practice, these values are used as a statement of safety and indicate when no actions need to be taken in a given exposure situation. Pharmaceutical manufacturing relies on ADIs for cleaning validation of process equipment and atypical extraneous matter investigations. To provide practical guidance for handling situations where relatively unstudied compounds with limited or no toxicity data are encountered, recommendations are provided on ADI values that correspond to three categories of compounds: (1) compounds that are likely to be carcinogenic, (2) compounds that are likely to be potent or highly toxic, and (3) compounds that are not likely to be potent, highly toxic or carcinogenic. Corresponding ADIs for these categories of materials are 1, 10, and 100 microg/day, respectively.

The Threshold of Toxicological Concern Concept in Risk Assessment

The concept that "safe levels of exposure" for humans can be identified for individual chemicals is central to the risk assessment of compounds with known toxicological profiles. The Threshold of Toxicological Concern (TTC) is a concept that refers to the establishment of a level of exposure for all chemicals, whether or not there are chemical-specific toxicity data, below which there would be no appreciable risk to human health. The concept proposes that a low level of exposure with a negligible risk can be identified for many chemicals, including those of unknown toxicity, based on knowledge of their chemical structures. The present paper aims to describe the history of the TTC principle, its use to date, its potential future applications and the incorporation of the TTC principle in the Risk Assessment paradigm.

Structure-based thresholds of toxicological concern (TTC): guidance for application to substances present at low levels in the diet

The threshold of toxicological concern (TTC) is a pragmatic risk assessment tool that is based on the principle of establishing a human exposure threshold value for all chemicals, below which there is a very low probability of an appreciable risk to human health. The concept that there are levels of exposure that do not cause adverse effects is inherent in setting acceptable daily intakes (ADIs) for chemicals with known toxicological profiles. The TTC principle extends this concept by proposing that a de minimis value can be identified for many chemicals, in the absence of a full toxicity database, based on their chemical structures and the known toxicity of chemicals which share similar structural characteristics. The establishment and application of widely accepted TTC values would benefit consumers, industry and regulators. By avoiding unnecessary toxicity testing and safety evaluations when human intakes are below such a threshold, application of the TTC approach would focus limited resources of time, cost, animal use and expertise on the testing and evaluation of substances with the greatest potential to pose risks to human health and thereby contribute to a reduction in the use of animals. An Expert Group of the European branch of the International Life Sciences Institute-ILSI Europe-has examined the TTC principle for its wider applicability in food safety evaluation. The Expert Group examined metabolism and accumulation, structural alerts, endocrine disrupting chemicals and specific endpoints, such as neurotoxicity, teratogenicity, developmental toxicity, allergenicity and immunotoxicity, and determined whether such properties or endpoints had to be taken into consideration specifically in a step-wise approach. The Expert Group concluded that the TTC principle can be applied for low concentrations in food of chemicals that lack toxicity data, provided that there is a sound intake estimate. The use of a decision tree to apply the TTC principle is proposed, and this paper describes the step-wise process in detail. Proteins, heavy metals and polyhalogenated-dibenzodioxins and related compounds were excluded from this approach. When assessing a chemical, a review of prior knowledge and context of use should always precede the use of the TTC decision tree. The initial step is the identification and evaluation of possible genotoxic and/or high potency carcinogens. Following this step, non-genotoxic substances are evaluated in a sequence of steps related to the concerns that would be associated with increasing intakes. For organophosphates a TTC of 18microg per person per day (0.3 microg/kg bw/day) is proposed, and when the compound is not an OP, the TTC values for the Cramer structural classes III, II and I, with their respective TTC levels (e.g. 1800, 540 and 90 microg per person per day; or 30, 9 and 1.5 microg/kg bw /day), would be applied sequentially. All other endpoints or properties were shown to have a distribution of no observed effect levels (NOELs) similar to the distribution of NOELs for general toxicity endpoints in Cramer classes I, II and III. The document was discussed with a wider audience during a workshop held in March 2003 (see list of workshop participants).

Risk assessment of packaging materials

Risk assessment of packaging materials provides a unique challenge. Human exposure to packaging materials and/or their components occurs from migration into foods. There are various methods for determining migration into foods. Unlike most food additives, these exposures typically are very small. Because of this, and since complete toxicological data sets are not always available for packaging materials, the US Food and Drug Administration (FDA) has developed a process to make the evaluation of packaging materials more efficient, instead of the extensive review normally required for food additives. This process is used to determine 'when the likelihood or extent of migration to food of a substance used in a food-contact article is so trivial as not to require regulation of the substance as a food additive'. This trivial level, also known as the threshold of regulation, was based upon a large database of carcinogenic potencies and was determined to be 1.5 microg/person day(-1). This was determined to 'be low enough to ensure that the public health is protected, even in the event that a substance exempted from regulation as a food additive is later found to be a carcinogen'. Substances not having structural alerts, or that are not known carcinogens or potent toxins, based on existing toxicological information, and are below the threshold value, are considered by the FDA to be exempted from regulation as food additives. The threshold of regulation approach used by the FDA provides an excellent model by which to evaluate the majority of packaging materials.

Polyethylene terephthalate recycling for food-contact applications: testing, safety and technologies: a global perspective

Studies were undertaken to determine the composition of five different types of post-consumer polyethylene terephthalate (PET) feedstreams to ascertain the relative amounts of food containers and non-food containers. Deposit post-consumer PET feedstreams contained approximately 100% food containers, whereas curbside feedstreams contained from 0.04 to 6% non-food containers. Analysis of the PET containers from the different type feedstreams after the containers were subjected to a commercial PET wash system and after processing with a proprietary decontamination technology was accomplished to determine the levels of compounds in the post-consumer PET after the various stages of processing. Comprehensive thermal desorption/GC/MS, purge and trap GC/MS purge and trap GC quantitation, PET dissolution and extraction GC analysis and PET dissolution HPLC analysis established the types and concentrations of compounds that absorb in the PET from the various types of postconsumer feedstreams. A total of 121 compounds were identified in the five different feedstreams. The concentration of absorbed compounds remaining in the deposit material and the non-food applications material after the commercial wash was 28 and 39mgkg(-1) respectively. Analysis of the feedstreams after subjecting the material to a proprietary decontamination process demonstrated the ability of removing all the absorbed compounds to a level below the level of the threshold of regulation. The safety of sourcing of post-consumer PET from food use applications verses non-food use applications of PET has been established.

Extending the threshold of regulation concept: de minimis limits for carcinogens and mutagens

Risk assessment processes for carcinogens are highly developed but risk assessment processes for mutagens are not well established. In the pharmaceutical industry, risk associated with exposure to carcinogens is tightly controlled. It is desirable to control risk associated with exposure to mutagens also, in spite of the greater uncertainty associated with the risk. In this paper, a published cancer potency database is used to frame the risk and to support risk management decisions. A de minimis exposure for mutagens is proposed and a decision matrix is presented to align available data with risk assessment approaches for carcinogens and mutagens.

Sources, pathways, and relative risks of contaminants in surface water and groundwater: a perspective prepared for the Walkerton inquiry

On a global scale, pathogenic contamination of drinking water poses the most significant health risk to humans, and there have been countless numbers of disease outbreaks and poisonings throughout history resulting from exposure to untreated or poorly treated drinking water. However, significant risks to human health may also result from exposure to nonpathogenic, toxic contaminants that are often globally ubiquitous in waters from which drinking water is derived. With this latter point in mind, the objective of this commission paper is to discuss the primary sources of toxic contaminants in surface waters and groundwater, the pathways through which they move in aquatic environments, factors that affect their concentration and structure along the many transport flow paths, and the relative risks that these contaminants pose to human and environmental health. In assessing the relative risk of toxic contaminants in drinking water to humans, we have organized our discussion to follow the classical risk assessment paradigm, with emphasis placed on risk characterization. In doing so, we have focused predominantly on toxic contaminants that have had a demonstrated or potential effect on human health via exposure through drinking water. In the risk assessment process, understanding the sources and pathways for contaminants in the environment is a crucial step in addressing (and reducing) uncertainty associated with estimating the likelihood of exposure to contaminants in drinking water. More importantly, understanding the sources and pathways of contaminants strengthens our ability to quantify effects through accurate measurement and testing, or to predict the likelihood of effects based on empirical models. Understanding the sources, fate, and concentrations of chemicals in water, in conjunction with assessment of effects, not only forms the basis of risk characterization, but also provides critical information required to render decisions regarding regulatory initiatives, remediation, monitoring, and management. Our discussion is divided into two primary themes. First we discuss the major sources of contaminants from anthropogenic activities to aquatic surface and groundwater and the pathways along which these contaminants move to become incorporated into drinking water supplies. Second, we assess the health significance of the contaminants reported and identify uncertainties associated with exposures and potential effects. Loading of contaminants to surface waters, groundwater, sediments, and drinking water occurs via two primary routes: (1) point-source pollution and (2) non-point-source pollution. Point-source pollution originates from discrete sources whose inputs into aquatic systems can often be defined in a spatially explicit manner. Examples of point-source pollution include industrial effluents (pulp and paper mills, steel plants, food processing plants), municipal sewage treatment plants and combined sewage-storm-water overflows, resource extraction (mining), and land disposal sites (landfill sites, industrial impoundments). Non-point-source pollution, in contrast, originates from poorly defined, diffuse sources that typically occur over broad geographical scales. Examples of non-point-source pollution include agricultural runoff (pesticides, pathogens, and fertilizers), storm-water and urban runoff, and atmospheric deposition (wet and dry deposition of persistent organic pollutants such as polychlorinated biphenyls [PCBs] and mercury). Within each source, we identify the most important contaminants that have either been demonstrated to pose significant risks to human health and/or aquatic ecosystem integrity, or which are suspected of posing such risks. Examples include nutrients, metals, pesticides, persistent organic pollutants (POPs), chlorination by-products, and pharmaceuticals. Due to the significant number of toxic contaminants in the environment, we have necessarily restricted our discussion to those chemicals that pose risks to human health via exposure through drinking water. A comprehensive and judicious consideration of the full range of contaminants that occur in surface waters, sediments, and drinking water would be a large undertaking and clearly beyond the scope of this article. However, where available, we have provided references to relevant literature to assist the reader in undertaking a detailed investigation of their own. The information collected on specific chemicals within major contaminant classes was used to determine their relative risk using the hazard quotient (HQ) approach. Hazard quotients are the most widely used method of assessing risk in which the exposure concentration of a stressor, either measured or estimated, is compared to an effect concentration (e.g., no-observed-effect concentration or NOEC). A key goal of this assessment was to develop a perspective on the relative risks associated with toxic contaminants that occur in drinking water. Data used in this assessment were collected from literature sources and from the Drinking Water Surveillance Program (DWSP) of Ontario. For many common contaminants, there was insufficient environmental exposure (concentration) information in Ontario drinking water and groundwater. Hence, our assessment was limited to specific compounds within major contaminant classes including metals, disinfection by-products, pesticides, and nitrates. For each contaminant, the HQ was estimated by expressing the maximum concentration recorded in drinking water as a function of the water quality guideline for that compound. There are limitations to using the hazard quotient approach of risk characterization. For example, HQs frequently make use of worst-case data and are thus designed to be protective of almost all possible situations that may occur. However, reduction of the probability of a type II error (false negative) through the use of very conservative application factors and assumptions can lead to the implementation of expensive measures of mitigation for stressors that may pose little threat to humans or the environment. It is important to realize that our goal was not to conduct a comprehensive, in-depth assessment of risk for each chemical; more comprehensive assessments of managing risks associated with drinking water are addressed in a separate issue paper by Krewski et al. (2001a). Rather, our goal was to provide the reader with an indication of the relative risk of major contaminant classes as a basis for understanding the risks associated with the myriad forms of toxic pollutants in aquatic systems and drinking water. For most compounds, the estimated HQs were < 1. This indicates that there is little risk associated with exposure from drinking water to the compounds tested. There were some exceptions. For example, nitrates were found to commonly yield HQ values well above 1 in- many rural areas. Further, lead, total trihalomethanes, and trichloroacetic acid yielded HQs > 1 in some treated distribution waters (water distributed to households). These latter compounds were further assessed using a probabilistic approach; these assessments indicated that the maximum allowable concentrations (MAC) or interim MACs for the respective compounds were exceeded <5% of the time. In other words, the probability of finding these compounds in drinking water at levels that pose risk to humans through ingestion of drinking water is low. Our review has been carried out in accordance with the conventional principles of risk assessment. Application of the risk assessment paradigm requires rigorous data on both exposure and toxicity in order to adequately characterize potential risks of contaminants to human health and ecological integrity. Weakness rendered by poor data, or lack of data, in either the exposure or effects stages of the risk assessment process significantly reduces the confidence that can be placed in the overall risk assessment. (ABSTRACT TRUNCATED)

Threshold of toxicological concern for chemical substances present in the diet: a practical tool for assessing the need for toxicity testing

The de minimis concept acknowledges a human exposure threshold value for chemicals below which there is no significant risk to human health. It is the underlying principle for the US Food and Drug Administration (FDA) regulation on substances used in food-contact articles. Further to this, the principle of Threshold of Toxicological Concern (TTC) has been developed and is now used by the Joint FAO/WHO Expert Committee on Food Additives (JECFA) in their evaluations. Establishing an accepted TTC would benefit consumers, industry and regulators, since it would preclude extensive toxicity evaluations when human intakes are below such threshold, and direct considerable time and cost resources towards testing substances with the highest potential risk to human health. It was questioned, however, whether specific endpoints that may potentially give rise to low-dose effects would be covered by such threshold. In this review, the possibility of defining a TTC for chemical substances present in the diet was examined for general toxicity endpoints (including carcinogenicity), as well as for specific endpoints, namely neurotoxicity and developmental neurotoxicity, immunotoxicity and developmental toxicity. For each of these endpoints, a database of specific no-observed-effect levels (NOELs) was compiled by screening oral toxicity studies. The substances recorded in each specific database were selected on the basis of their demonstrated adverse effects. For the neurotoxicity and developmental neurotoxicity databases, it was intended to cover all classes of compounds reported to have either a demonstrated neurotoxic or developmentally neurotoxic effect, or at least, on a biochemical or pharmacological basis were considered to have a potential for displaying such effects. For the immunotoxicity endpoint, it was ensured that only immunotoxicants were included in the database by selecting most of the substances from the Luster et al. database, provided that they satisfied the criteria for immunotoxicity defined by Luster. For the developmental toxicity database, substances were selected from the Munro et al. database that contained the lowest NOELs retrieved from the literature for more than 600 compounds. After screening these, substances showing any effect which could point to developmental toxicity as broadly defined by the US were recorded in the database. Additionally, endocrine toxicity and allergenicity were addressed as two separate cases, using different approaches and methodology. The distributions of NOELs for the neurotoxicity, developmental neurotoxicity and developmental toxicity endpoints were compared with the distribution of NOELs for non-specific carcinogenic endpoints. As the immunotoxicity database was too limited to draw such a distribution of immune NOELs, the immunotoxicity endpoint was evaluated by comparing immune NOELs (or LOELs-lowest-observed-effect levels-when NOELs were not available) with non-immune NOELs (or LOELs), in order to compare the sensitivity of this endpoint with non-specific endpoints. A different methodology was adopted for the evaluation of the endocrine toxicity endpoint since data currently available do not permit the establishment of a clear causal link between endocrine active chemicals and adverse effects in humans. Therefore, this endpoint was analysed by estimating the human exposure to oestrogenic environmental chemicals and evaluating their potential impact on human health, based on their contribution to the overall exposure, and their estrogenic potency relative to endogenous hormones. The allergenicity endpoint was not analysed as such. It was addressed in a separate section because this issue is not relevant to the overall population but rather to subsets of susceptible individuals, and allergic risks are usually controlled by other means (i.e. labelling) than the Threshold of Toxicological Concern approach. (ABSTRACT TRUNCATED)

A tiered approach to threshold of regulation

This paper presents methods for extending the principle of a single "threshold of regulation" to a range of dietary concentrations between 0.5 and 15 parts per billion by using structure-activity relationships, genotoxicity, and short-term toxicity data. The database used to develop the FDA's threshold of regulation was examined to determine whether structural parameters or the result of certain short-term toxicity tests could be used to define a subset of less potent substances that supports higher threshold levels. In addition, results of reproductive toxicity tests for 3306 compounds and other multidose toxicity tests for 2542 compounds were compared with the database of carcinogenic potencies to establish that carcinogenic endpoints are the most conservative toxicity endpoint for establishing thresholds of regulation.

A procedure for the safety evaluation of flavouring substances. Joint FAO/WHO Expert Committee on Food Additives

This review describes a procedure for the safety evaluation of flavouring substances. Over 2500 flavouring substances are currently in use in food. While toxicity data do not exist on all flavouring substances currently in use, within structurally related groups of flavouring substances many do have toxicity data and this information along with knowledge of structure-activity relationships and data on the daily intake provides a framework for safety evaluation. The safety evaluation procedure provides a scientifically based practical method of integrating data on intake, structure-activity relationships, metabolism and toxicity to evaluate flavouring substances in a timely manner. The procedure has been used recently by the Joint FAO/WHO Expert Committee on Food Additives (JECFA) to evaluate a total of 263 flavouring substances.

Studies on the potential for genotoxic carcinogenicity of fragrances and other chemicals

The potential of fragrances, physiological chemicals, natural products and a group of randomly selected chemicals to induce cancers by a genotoxic mechanism (i.e. "genotoxic" carcinogenesis) was compared using structure-activity relationships (SAR) models. Fragrances are significantly less likely to induce genotoxic carcinogenicity than randomly selected chemicals or natural products. With respect to the latter potential, fragrances were indistinguishable from normal mammalian physiological constituents.

Principles for the safety evaluation of flavouring substances

This paper reviews efforts by various organizations to develop principles and procedures for the safety evaluation of flavouring substances. Critical factors considered in safety evaluation of these substances include their level of human intake, ease of metabolism to innocuous end-products and the margin of safety between no-observed-effect levels in animal studies and human intakes. These factors form the basis for the principles and criteria laid out in this paper.

Methods and approaches used by FDA to evaluate the safety of food packaging materials

In the Federal Register of July 17 1995 (60 FR 36582), the US Food and Drug Administration (FDA) established a 'threshold of regulation' process. This process was established for determining when the extent of migration to food is so trivial that safety concerns would be negligible. The process exempts materials in food-contact articles whose use results in dietary concentrations at or below 0.5 ppb (microgram/kg) from the food additive listing regulation requirement. Carcinogens or substances that may be carcinogens are excluded from this regulation. This paper explores some of the ramifications of the threshold of regulation policy with respect to traditional migration testing. It examines the use of the threshold approach and migration modelling to estimate food additive exposures. These results indicate that modelling may be a reasonable alternative to traditional migration testing.

The threshold of regulation and its application to indirect food additive contaminants in recycled plastics

Recycled plastics have been used in food-contact applications since 1990 in various countries around the world. To date, there have been no reported issues concerning health or off-taste resulting from the use of recycled plastics in food-contact applications. This is due to the fact that the criteria that have been established regarding safety and processing are based on extremely high standards that render the finished recycled material equivalent in virtually all aspects to virgin polymers. The basis for this conclusion is detailed in this document.

Mutagenic nitroarenes, diesel emissions, particulate-induced mutations and cancer: an essay on cancer-causation by a moving target

Initial analyses of the lung tumors seen in rats exposed for their lifetime to elevated levels of the emissions of diesel engines suggested that they were due to powerful mutagens and carcinogens (PAHs, nitro PAHS) absorbed onto the diesel particles. However, further studies showed that carcinogenicity occurred only under conditions that resulted in impaired lung clearance ('overloading') leading to inflammatory reactions and other pathologic sequelae. These observations together with the findings that carbon black, a model for diesel particles devoid of organic mutagens and carcinogens, also induced lung cancers under conditions of overloading led to the suggestion that the cancers resulted from a non-genotoxic mechanism. However, the further finding that inert particulate carcinogens devoid of organics, induce mutations has led to a re-evaluation of the role of mutations in lung carcinogenesis caused by particles and the relevance of the rat model to humans. This is especially timely as epidemiological studies suggest that humans may develop lung cancers following occupational exposure to diesel emission by a mechanism unlikely to involve lung overloading. Finally, the recent recognition that environmental PM-10 (respiratory size particles) may be responsible for a significant portion of human morbidity and mortality, ensures that the health effect of diesel emissions will continue to receive scrutiny as they contribute to the PM-10 load.

Application of structural concepts to evaluate the potential carcinogenicity of natural products

The expert structure-activity relational system CASE/MULTICASE was used to obtain an assessment of the possible carcinogenicity of selligueain A, a plant-derived sweetener. Based upon a series of authoritative data bases it was predicted that this chemical had some marginal potential for being a 'non-genotoxic' rodent carcinogen. The relevance of this potential to possible human health risks is problematic. Still, given the fact that successful sweetener may be widely consumed, should this chemical be developed further, experimental determinations of its potential carcinogenicity appear in order.

An examination of the potential "genotoxic" carcinogenicity of a biopesticide derived from the neem tree

Structural analyses of azadirachtin, a promising biopesticide recently introduced into the United States, indicates that this natural product has the potential for acting as a "genotoxic" carcinogen. In view of the fact that genotoxic carcinogens are regarded as presenting a potential carcinogenic risk to humans, the present finding suggests that the possible metabolism of azadirachtin to DNA-reactive products be evaluated experimentally.

United States of America and European regulation of food packaging: finding common ground to reach a common goal

There are pronounced differences between the USA approach to the regulation of food packaging and the system being adopted in the European Economic Community (EEC). These differences have significant implications for the efficient regulation of packaging materials and for achieving the common goal of regulatory harmonization. The United States effects preclearance of packaging materials by generic regulation, a modified 'positive list' system with certain jurisdictional exclusions. Distinguishing characteristics of the USA system include exemptions for materials that are 'prior sanctioned', 'generally-recognized-as-safe' (GRAS) or 'not reasonably expected to become a component of food'. The USA also embraces the application of the concept of Estimated Dietary Intake and use limitations to take into account likely exposure and, thereby, delimit the requirements for toxicological data. The EEC, on the other hand, is moving towards adoption of a strict positive list system under which no substance may be used in making a package or packaging material unless it is on the positive list on the basis of a toxicological conclusion as to the general safety of the substance. This paper examines the logical and philosophical underpinnings of both systems and the potential for common sense application of de minimis, or regulatory threshold principles, and worldwide use of the Estimated Dietary Intake concept, to help bring about a measure of harmonization consistent with the safe and efficient regulation of food packaging materials.

An overview of the report: correlation between carcinogenic potency and the maximum tolerated dose: implications for risk assessment

Current practice in carcinogen bioassay calls for exposure of experimental animals at doses up to and including the maximum tolerated dose (MTD). Such studies have been used to compute measures of carcinogenic potency such as the TD50 as well as unit risk factors such as q1 * for predicting low-dose risks. Recent studies have indicated that these measures of carcinogenic potency are highly correlated with the MTD. Carcinogenic potency has also been shown to be correlated with indicators of mutagenicity and toxicity. Correlation of the MTDs for rats and mice implies a corresponding correlation in TD50 values for these two species. The implications of these results for cancer risk assessment are examined in light of the large variation in potency among chemicals known to induce tumors in rodents.