The cancer threshold of toxicological concern (TTC) in relation to foodstuffs and pharmaceuticals: A potentially useful concept compromised by a dubious derivation

The cancer threshold of toxicological concern (TTC) as determined by Kroes et al. in 2004 (0.15 µg/day and 1.5 µg/day at risk levels of 1 in 106 or 105, respectively) has been uncritically employed as a key metric in multiple regulatory guidance documents. There are numerous concerns regarding transparency and the highly conservative methodology in relation to its derivation; moreover, no formal confirmation has been undertaken by any regulatory body prior to its adoption. A recent joint report from the European Food Safety Authority and World Health Organization follows this trend, largely replicating previous conclusions and downplaying the need for a re-assessment. This view is challenged by Boobis et al. who confirm concerns regarding lack of transparency and stress that several of the assumptions and approaches used previously have been superseded by advances in knowledge; they recommend as a first step construction of a new dataset derived from the Carcinogenic Potency Database focusing on mutagenic DNA-reactive rodent carcinogens and a critical assessment of the relevance and reliability of carcinogenicity data. This type of approach is supported with two key exceptions: inclusion of data from the ToxTracker assay which provides a direct readout of DNA reactivity, and use of appropriate epidemiological data on acrylamide (AA) to determine a benchmark for human exposure to a typical DNA-reactive rodent carcinogen. It is concluded that a robust re-evaluation using an appropriate dataset and methodology is urgently needed to ensure the integrity of the cancer TTC before it is employed in its present form even more widely.

Regulatory risk assessments: Is there a need to reduce uncertainty and enhance robustness? Update on propylparaben in relation to its EU regulatory status

Over 10 years ago, propylparaben (propyl- p-hydroxybenzoate; PP) was withdrawn as a permitted food preservative in the EU based entirely on findings reported in a single dietary study in juvenile rats claiming to show adverse effects on male reproductive parameters [Oishi S. Effects of propyl paraben on the male reproductive system. Food Chem Toxicol 2002; 40(12): 1807 -1813]. Subsequent data reviews have cast serious doubt on the validity of the Oishi results, mainly in relation to aberrant concurrent-control values, and in two further comprehensive studies using neonatal and juvenile rats there were no adverse effects in males at oral doses up to 1000 mg/kg/day. By contrast, juvenile animal toxicity data on the two paraben preservatives currently permitted in the EU as food additives (methylparaben and ethylparaben) are non-robust and rudimentary. Although PP is a permitted preservative in cosmetics its use pattern is highly restricted based mainly on the results of a screening study in the rat using butylparaben as test material, and not taking into account the more recent data on PP. The European Medicines Agency has determined a permitted daily exposure of 2 mg/kg for PP, which applies to both adult and paediatric patients, based on an oral no-observed-adverse-effect level of 100 mg/kg/day in females, treatment-related changes suggestive of an estrogenic effect being noted at 1000 mg/kg/day. The weight of evidence strongly supports a toxicological re-evaluation of PP regarding its use in foodstuffs and cosmetics in the EU, with a view to reinstatement as a food additive, consistent with its status in other major jurisdictions.