Industry
Eyes Data Quality Challenge Of EPA Formaldehyde Risk Analysis
Posted: September 14, 2010 Industry is harshly
criticizing EPA's strict draft risk assessment of formaldehyde, arguing that
the risk estimates in the assessment are too conservative and raising the
possibility of a future Data Quality Act (DQA) challenge if EPA does not
substantially revise the assessment. Comments
filed with EPA by
several trade associations, including the American Chemistry Council (ACC),
American Forest & Paper Association (AFPA), American Petroleum Institute
and others, question the assessment's compliance with the DQA and raise other
issues about the document. "EPA has failed to
comport with the explicit [DQA] Guidelines as well as EPA Cancer
Guidelines," according to ACC's Aug. 31 comments. An ACC source tells Risk
Policy Report that while the association has not filed a DQA challenge
regarding the assessment, raising the issue in public comments preserves the
opportunity to do so at a later time. The AFPA and other groups
in their comments, further say the draft assessment falls "far short of meeting
the Office Management and Budget's [DQA] guidelines as well as the agency's own
specific guidelines. Among some of the serious deficiencies of the current
draft assessment is its failure to consider the best available science, failure
to use a sound weight-of-the evidence approach, and a lack of transparency and
objectivity." Comments from the Methanol Institute and the American
Coatings Association (ACA) raise similar concerns. The questions come as
industry is ramping up DQA challenges to EPA risk analysis and other risk-based
decisions at the agency. For example, the ACC filed a petition questioning
EPA's action plans for the plastic chemicals bisphenol-A and phthalate esters,
the Methanol Institute filed a petition over the agency's assessment of methanol's
risks, industry groups filed a petition questioning the agency's arsenic
assessment and the ACA filed a petition regarding EPA's lead public service
announcements. The industry comments on
the formaldehyde assessment reiterate questions also raised by other agencies,
including the Agency for Toxic Substances & Disease Registry (ATSDR),
Defense Department and National Aeronautics & Space Administration. The
groups question the strength of the epidemiological evidence that EPA bases its
cancer findings and cancer potency estimate on, as well as the agency's
hypothesis for how formaldehyde can cause leukemia. The groups also question
the inclusion of a new epidemiological study, known as the Zhang study, which
EPA relied on in deciding that formaldehyde is a human carcinogen. The
International Agency for Research on Cancer and a panel of expert advisers to
the National Toxicology Program also used the study in similar decisions about
carcinogenicity. The industry comments
also criticize EPA's inclusion of a mutagenic mode of action in the assessment,
which requires the agency to use a strict, linear estimate of low-dose effects.
The groups argue that the use of the conservative assessment practice results
in an assessment that is unrealistic and risk standards that cannot be met
because levels of formaldehyde in human breath exceed them. The American Petroleum
Institute (API) in Aug. 31 comments notes that EPA's inhalation unit risk
factor, or estimate of cancer potency, is 0.13 parts per million (ppm), corresponding
to an exposure criterion of 7.7 parts per trillion (ppt). "Based on current
levels of formaldehyde that humans are exposed to via inhalation of ambient,
indoor, and work room air, the cancer risks estimated using EPA's draft unit
risk factor are not plausible or realistic," according to the comments.
"This brings into question the utility and technological feasibility of
achieving an exposure criterion of 7.7 ppt for formaldehyde. EPA's cancer risk
estimates are also not plausible if one considers the normal levels of
formaldehyde present in human tissues." 'Typical Range'
Indoors API quotes studies
indicating "overall" outdoor levels of formaldehyde ranging between
0.56 and 36.31 parts per billion (ppb) and a "typical range" of
formaldehyde in houses in the United States of 11 and 285 ppb. "EPA's
draft value of 7.7 ppt is 4,000-fold lower than the mean indoor level and
37,000-fold lower than peak indoor levels. EPA's cancer risk assessment is
based on the assumption that a single peak formaldehyde exposure any time
during one's lifetime can cause leukemia. Therefore, using the peak indoor
exposure is a relevant comparison," according to API's comments. Other comments quote a
2007 National Academy of Sciences report statistic that exhaled human breath
contains 2 ppb formaldehyde. Several of the industry
groups also quote a study published last month in Toxicological Sciences by
Lu et al, which compares endogenous and exogenous amounts of formaldehyde in
the blood of rats exposed to the chemical. The study "casts serious
questions as the biological plausibility of EPA's proposed" biological
means of how the chemical could cause leukemia, according to API. Both API and AFPA also
raise concerns about EPA's non-cancer risk estimate, the reference concentration,
or the amount of formaldehyde the agency considers safe to breathe on a daily
basis over a lifetime. The groups question EPA's decision to use studies of
occupants of mobile homes, rather than studies of human volunteers exposed to
formaldehyde in chambers. The latter are more robust, the organizations argue. "Chamber studies
preclude confounding exposures, reduce or eliminate false positives, and
provide for accurate measure of exposure, in addition to other study
advantages," according to AFPA's Aug. 31 comments. "EPA's reasons for
rejecting controlled chamber studies are without sound scientific merit, and
need to be reexamined." ACC urges EPA to consider
the 0.3 ppm standard as "conservative and protective against sensory
irritation" that it says authoritative international agencies have
adopted, including the Organization for Economic Cooperation and Development,
National Academy of Sciences, ATSDR, and World Health Organization, among
others. -- Maria Hegstad |