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14  SECTION | I General




  VetBooks.ir  the Lovelace Institute with rats exposed to low dilutions (as  independent evaluation of the evidence, which concluded
                The Health Effects Institute sponsored a study at
                                                                there were serious shortcomings in the IARC evaluation.
                                                                The results of the independent evaluations have been pub-
             low as 20 to 1) of exhaust from a 2007 EPA-compliant
             engine fueled with ultra-low sulfur fuel. The highest  lished in a special Supplement to Critical Reviews
             exposures were less than 1% of the particle matter concen-  in Toxicology with a commentary I prepared as editor of
             trations studied earlier using traditional diesel technology  the journal (McClellan, 2016a,b; Williams et al., 2016a,b;
             engines. In contrast to the findings observed earlier with the  Solomon, 2016; Brusick et al., 2016; Acquavella et al.,
             traditional diesel engines, an excess of lung cancer was not  2016). I encourage individuals to read both the original
             observed (Mauderly et al., 1987; McDonald et al., 2015).  IARC report and the reports prepared by the reevaluation
                Almost concurrently, results were published by  team to gain an appreciation of the complexities of
             NIOSH and NCI investigators on a large Diesel Exhaust  the IARC cancer hazard classification process and the
             in Miners Study (DEMS) (Attfield et al., 2012; Silverman  uncertainties associated with evaluating the carcinogenic
             et al., 2012). The DEMS involved 12,315 workers from  hazard of a single, well-studied chemical such as glypho-
             eight nonmetal mines (three potash, three trona, one salt,  sate. This will also give the reader an appreciation of the
             and one limestone) whose exposures and vital data were  role of both epidemiological and animal evidence in the
             assessed through 1997. Thus, these exposures were from  cancer-hazard classification process.
             emissions from traditional technology diesel engines. The  Increasingly, the “precautionary principle” has dominated
             initial reports by the NIOSH/NCI investigators revealed a  approaches to regulation of products and technologies. The
             positive association between respirable elemental carbon  concept took hold first within Europe and was codified by
             exposure (extrapolated from CO measurements) and   the European Commission (2002), more recently its use has
             excess lung cancer. These findings were instrumental in  been advocated in the United States. In its most simple form
             an IARC (2012) panel upgrading the classification of die-  it argues that if the product or technology has not or cannot
             sel exhaust exposure from a probable human carcinogen  be viewed as safe then the product or technology should be
             to a human carcinogen. Later, the HEI evaluated the most  replaced or not used. It is obvious that the “devil is in the
             recent epidemiological findings, including the DEMS  details” with regard to the basis for characterizing what is
             results and concluded that the findings could be used for  safe or not safe. There is a continuum from safe products or
             quantitative risk assessment in addition to their use in  technologies to highly hazardous products and technologies.
             cancer hazard classification (HEI, 2015).          Indeed, some highly hazardous products may be used in a
                More recently, a team I have been associated with  controlled manner so they do not pose a significant health
             gained access to the DEMS data, replicated the original  risk. Some advocates of the “precautionary principle” point
             analyses and then extended the analyses. The use of alter-  to thousands of untested chemicals and argue they should be
             native exposure assessments, which were viewed as being  tested or banned. I would argue that a critical review of past
             equal to or superior to the original DEMS estimates,  experience with many of these chemicals or closely related
             yielded substantially reduced lung cancer hazard esti-  chemicals provides a sound basis for their continued use.
             mates. When radon was included in the analyses the haz-  Quite frankly, additional extensive testing using laboratory
             ard estimates were further reduced and generally no  animals may not be warranted. Moreover, I am concerned
             longer statistically significant (Moolgavkar et al., 2015;  that many of the in vitro cellular and molecular assays have
             Crump et al., 2015, 2016). These findings emphasize that  not yet been appropriately validated as predictors of the pres-
             a high degree of caution should be exercised in extrapo-  ence or absence of adverse health effects in humans.
             lating the DEMS findings selectively or in toto to other  The “precautionary principle” is a core element of the
             populations or in using them for quantitative risk assess-  Registration, Evaluation, Authorization, and Restriction
             ment. This body of work emphasizes the importance of  of Chemicals (REACH) program established by the
             important epidemiological data sets being made available  European Commission (2006). More details are available
             for analysis by multiple investigators, especially when the  at REACH (2011). Thoughtful reviews of the REACH
             results have public policy impact. The same applies to  program have been written by deAvila and Sandberg
             large data sets assembled in studies by veterinary toxicol-  (2006) and Williams et al. (2009).
             ogists of animal populations. Such use should be part of  Potential changes in how chemicals are regulated in
             the planning process when the study is designed.   the United States have been debated for decades. That
                A recent IARC monograph program decision of spe-  debate resulted in passage in 2016 of the Frank R.
             cial interest to those of us interested in agricultural and  Lautenberg Chemical Safety for the 21st century Act
             food production issues concerns the widely used herbi-  amendments to the Toxic Substances Control Act signed
             cide, glyphosate, frequently marketed as Roundup. IARC  by the President of the United States on June 22, 2016
             (2015) evaluated the epidemiological, animal, and sup-  (TSCA, 2016). These amendments establish mandatory
             porting evidence on glyphosate and classified it as  requirements for the USEPA to evaluate existing chemi-
             a probable human carcinogen. This action prompted an  cals, have all new chemicals evaluated before commercial
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