Incorporating potency into EU classification for carcinogenicity and reproductive toxicity

Although risk assessment, assessing the potential harm of each particular exposure of a substance, is desirable, it is not feasible in many situations. Risk assessment uses a process of hazard identification, hazard characterisation, and exposure assessment as its components. In the absence of risk assessment, the purpose of classification is to give broad guidance (through the label) on the suitability of a chemical in a range of use situations. Hazard classification in the EU is a process involving identification of the hazards of a substance, followed by comparison of those hazards (including degree of hazard) with defined criteria. Classification should therefore give guidance on degree of hazard as well as hazard identification. Potency is the most important indicator of degree of hazard and should therefore be included in classification. This is done for acute lethality and general toxicity by classifying on dose required to cause the effect. The classification in the EU for carcinogenicity and reproductive toxicity does not discriminate across the wide range of potencies seen (6 orders of magnitude) for carcinogenicity and for developmental toxicity and fertility. Therefore potency should be included in the classification process. The methodology in the EU guidelines for classification for deriving specific concentration limits is a rigorous process for assigning substances which cause tumours or developmental toxicity and infertility in experimental animals to high, medium or low degree of hazard categories by incorporating potency. Methods are suggested on how the degree of hazard so derived could be used in the EU classification process to improve hazard communication and in downstream risk management.     

Use of read-across and tiered exposure assessment in risk assessment under REACH – A case study on a phase-in substance

REACH requests the exploration of alternative strategies for hazard identification before resorting to (in vivo) testing. Here, we combined read-across as non-testing strategy with a tiered exposure assessment for the risk characterisation of 1-methoxypropan-2-ol (PGME) as a representative for phase-in substances to be registered under REACH. Read-across from the selected source substances provided data which were comparable with experimental data available for target substance PGME, resulting in a realistic starting point for both qualitative and quantitative risk assessment. Greater variability was observed in the exposure estimates from a first Tier model (ECETOC TRA) or less conservative further Tier models (Stoffenmanager; RISKOFDERM), when these results were compared with results from a data-rich approach using measured data.     

Release of nanomaterials from solid nanocomposites and consumer exposure assessment – a forward-looking review

The European chemical legislation requires manufacturers and importers of chemicals to do consumer exposure assessment when the chemical has certain hazards associated to it (e.g. explosive, carcinogenicity, and hazardous to the aquatic environment), but the question is how this obligation can be met in light of the scientific uncertainty and technical challenges related to exposure assessment of nanomaterials. In this paper, we investigate to what extent the information and data in the literature can be used to perform consumer exposure assessment according to the REACH requirements and we identify and discuss the key data needs and provide recommendations for consumer exposure assessment of nanomaterials. In total, we identified 76 studies of relevance. Most studies have analyzed the release of Ag and TiO₂ from textiles and paints, and CNT and SiO₂ from nanocomposites. Less than half of the studies report their findings in a format that can be used for exposure assessment under REACH, and most do not include characterization of the released particles. Although inhalation, dermal, and oral exposures can be derived using the guidelines on how to complete consumer exposure assessments under REACH, it is clear that the equations are not developed to take the unique properties of nanomaterials into consideration. Future research is therefore needed on developing more generalized methods for representing nanomaterial release from different product groups at relevant environmental conditions. This includes improving the analytical methods for determining nanomaterial alteration and transformation, as well as quantification, which could subsequently lead to more nano-specific consumer exposure assessment models.     

The role of professional judgment in chemical hazard assessment and communication

Most hazard assessment guidelines and regulatory requirements--both nationally and internationally--explicitly advocate the use of professional judgment in hazard assessment. However, the practical application of such judgment (i.e., how and when that judgment should be applied) is often left to the assessor's discretion. This can lead to inconsistent guidance on the use, handling, and disposal of chemicals and can ultimately result in ineffective hazard communication and chemical management. This paper traces the regulatory rationale and legislative conventions for applying professional judgment in hazard assessment to key global regulations and professional standards. A series of guidelines for applying professional judgment are drawn from these regulations and standards, consistent with sound toxicological concepts and principles. The guidelines are illustrated by cogent examples drawn from the experiences of professional toxicologists and industrial hygienists charged with complying with the norms of hazard assessment. We contend that these guidelines and supporting examples are fully compliant with international regulations, decision-neutral with regard to the stringency of the assessment, and reflective of the harmonized efforts to develop more effective and complete hazard communications. We discuss the regulatory ramifications and needs for better definition of professional judgment in hazard assessments under GHS and REACH.     

Human biomonitoring as a pragmatic tool to support health risk management of chemicals--examples under the EU REACH programme

REACH requires health risk management for workers and the general population and introduced the concept of Derived No-Effect Level (DNEL). DNELs must be derived for all substances that are classified as health hazards. As with analogues to other health-risk based guidance values, such as reference doses (RfDs) and tolerable daily intakes (TDIs), risk to health is considered negligible if the actual exposure is less than the DNEL. Exposure assessment is relatively simple for occupational situations but more complex for the general public, in which exposure may occur via multiple pathways, routes, and media. For such complex or partially defined exposure scenarios, human biomonitoring gives a snapshot of internal or absorbed dose of a chemical and is often the most reliable exposure assessment methodology as it integrates exposures from all routes. For human risk management human biomonitoring data can be interpreted using the recently developed concept of Biomonitoring Equivalents (BE). Basically, a BE translates an established reference value into a biomarker concentration using toxicokinetic data. If the results of an exposure assessment using human biomonitoring indicate that the levels measured are below the DNEL-based BE (BE(DNEL)), it would indicate that the combined exposure via all potential exposure routes is unlikely to pose a risk to human health and that health risk management measures might not be needed. Hence, BEs do not challenge existing risk assessments but rather build upon them to help risk management, the ultimate goal of any risk assessment. A challenge in implementing this approach forms the limited availability of toxicokinetic information for many substances. However, methodologies such as generic physiologically-based toxicokinetic models, which allow estimation of biomarker concentrations based on physicochemical properties, are being developed for less data-rich chemicals. Use of BE by regulatory authorities will allow initial screening of population exposure to chemicals to identify those chemicals requiring more detailed risk and exposure assessment, assisting in priority setting and ultimately leading to improved product stewardship and risk management.     

A survey and analysis of states' methodologies for deriving drinking water guidelines for chemical contaminants

Data from a national survey questionnaire regarding the development of guidelines for chemical contaminants in drinking water were collected from all 50 states. Twenty-three states develop at least some of their own guidelines; the other 27 states rely on guidelines previously developed by the U.S. Environmental Protection Agency (USEPA) or by other states. States which derive guidelines generally employ toxicological criteria and risk assessment methodologies developed by the USEPA. Fourteen of the twenty-three states that develop their own guidelines depend on cancer potency factors derived by the USEPA to establish risk-based concentrations for carcinogens. Most of the states develop guidelines based on preventing possible excess cancer risk greater than one in one million. Seventeen of these twenty-three states rely on oral reference doses (RfDs) to derive guidelines for noncarcinogens. Examination and clarification of the states' approaches to guideline derivation reveal that although similar risk assessment techniques are generally employed, differences in assumptions, chemical classifications, and uncertainty factors may lead to variation in resultant guidance levels. Improved communication and coordination between states and the federal government may help reduce the variations and inconsistencies among the states in establishing drinking water guidelines for chemical contaminants.     

About hazard and risk assessment: Regulatory approaches in assessing safety in the European Union chemicals legislation

Hazard classification and labelling is the main and basic requirement for all industrial and consumer chemicals in the European Union, if they are not regulated under more specific legislation such as drugs, food ingredients or cosmetics. The first approach in hazard classification is hazard identification describing the hazardous properties of chemicals. Refinements in the classification criteria include the assessment of toxic potency (hazard characterisation) where feasible and the possibility to set higher or lower specific concentration limits for classification. In the past only a minor portion of the classified chemicals underwent a risk assessment including exposure assessment and risk characterisation. Risk assessment will become more frequent with the implementation of REACH. However, as risk assessment is rather labour-intensive even under REACH risk assessment will be performed in a targeted approach for a selected number of chemical substances while hazard classification and labelling will remain the basic approach for all chemicals.     

Outline on risk assessment programme of existing substances in the European Union

Various programmes have been developed by national and international organisations to improve chemical safety of existing substances. The European Union Programme came into force on 4 June 1993. This programme gives a legal requirement that the manufacturer or the importer has to deliver data on substances produced or imported. The risk assessment process in the EU provides that every member state formally selects priority substances. To perform the risk characterisation for a priority substance, exposure assessment and the dose (concentration)-response (effect) assessment are conducted. Comparing the information on exposure to the effects identified by a hazard identification of the substance the risk assessor has to decide whether there is or there is no need for further information or testing or whether there is need for limiting the risks. The draft risk assessment report is sent to the OECD as European contribution to the programme on existing substances for discussion with OECD-member countries. A final decision on the substance is performed by the member states of the European Union.     

REACH exposure assessment of anticorrosive paint products--determination of exposure from application and service life to the aquatic environment

The European Community Regulation on the registration, evaluation, authorisation and restriction of chemicals (REACH) introduced exposure scenarios describing safe use quantitatively, and enhancing the importance of scientific based exposure assessments. This paper presents methods to determine exposure from the airless spray application of anti-corrosive paint and leaching of painted articles submerged in seawater, to establish whether it is possible to test these exposures in a reproducible and feasible way. The paper also presents results from using the methods in order to assess how well the default values recommended under REACH coincide with the tested values and corresponding values available in literature. The methods used were feasible under laboratory conditions. The reproducibility of the application study was shown to be good and all analyses of the leaching showed concentrations below detection limit. More replicates will be required to validate the reproducibility of the growth inhibition tests. Measured values for the present overspray scenario were between, and the leaching values below, values from REACH guidelines and emission scenario documents. Further development of the methods is recommended.     

Improving REACH

The European Commission has proposed a new system for chemicals control, the REACH system. The objectives of REACH with respect to risk assessment can be summarized in the form of two overarching goals. First, REACH aims at improved knowledge about the properties and the uses of individual chemical substances. Secondly, REACH is intended to increase the speed and efficiency of the risk assessment process and to make producers and importers of chemicals responsible for this process. The implementation of the REACH proposal will lead to increased availability of toxicological information but not to the extent that would be needed to achieve a sound scientific basis for risk assessment of individual substances. In this paper, we propose certain amendments of the current REACH proposal. The purpose of these proposals is to improve priority-setting and testing strategies and to simplify the risk assessment procedures.     

REACH,non-testing approaches and the urgent need for a change in mind set

The objectives of REACH cannot be achieved under the current risk assessment approach. A change in mind set among all the relevant stakeholders is needed: risk assessment should move away from a labor-intensive and animal-consuming approach to intelligent and pragmatic testing, by combining exposure and hazard data effectively and trying to group chemicals (category approaches). The focus should be on reducing the overall uncertainties of 30,000 chemicals while acknowledging the existence of the uncertainty paradox: reducing uncertainty in the assessment of individual chemicals following the classical chemical-by-chemical approach as we have in previous decades will result in a prolongation of uncertainty for the entire group of 30,000 chemicals as a whole. With the first REACH registration deadline (2010) rapidly approaching, a mind set change is urgently needed. We can speed up the regulatory acceptance process, starting with the maximum use of currently available exposure and hazard data, tools and models. Optimal use should also be made of experimental exposure and hazard data generated under REACH. Only such an approach will make it possible to obtain a sufficient level of information within the time frame of REACH. A much more intensive dialogue between stakeholders is necessary.     

Exposure-based waiving under REACH

Within the REACH framework, but also within OECD, there is understanding that for reasons of animal welfare, costs and logistics, it is important to limit the number of tests to be conducted. Exposure-based waiving (EBW) is a potentially important element in testing strategies. This publication describes criteria for exposure-based waiving as foreseen in the REACH regulation and gives more detail to the REACH requirements for exposure-based waiving The principle behind any EBW is that there are situations when human or environmental exposures are so low or infrequent that there is a very low probability that the acquisition of additional effect information may lead to an improvement in the ability to manage risk. EBW therefore is risk-based and needs thorough knowledge on exposure as well as on effects criteria. Both elements are discussed: exposure models are analysed and the uncertainty in their predictions discussed as well as no-effect criteria such as the threshold of toxicological concern. Examples of EBW are provided for environmental, consumer and worker exposure. REACH only allows EBW in a limited number of cases with constraints on tonnage levels, types of tests to be waived and the need for a thorough ES and exposure assessment throughout the life cycle of a chemical and for all human exposure routes and environmental pathways. EBW will only be considered a real option by industry if a cost-benefit analysis shows an advantage, which may heavily depend on the weighing factor one applies for the non-use of experimental animals.     

Narrow-and-sharp or broad-and-blunt--regulations of hazardous chemicals in consumer products in the European Union

Chemicals are incorporated into a vast number of consumer products, and it has been recognized that considerable exposures of humans and the environment to chemicals are due to diffuse emissions from everyday products. Different approaches to the management of risks concerning chemicals in products are discussed on the international arena, but no general strategy has yet been adopted. The aim of this study is to investigate how health and environmental risks associated with chemicals in consumer products are currently managed in European Union legislations, mainly by the Toys Directive, the RoHS Directive, and REACH. Significant differences were found between the risk reduction strategies in these legislations, including substance prioritization, type of restrictions and requirements, and information dissemination to consumers. REACH regulates chemicals in products to a limited extent, and via quite complicated processes. Product-specific rules are therefore useful supplements to REACH for regulating chemicals in products. The combined effects of the RoHS and WEEE directives seem to be effective in promoting substitution of substances identified as problematic in electrical and electronic equipment, and it is recommended that the possibility to develop similar systems should be considered also for other product categories.     

The challenge of reproductive and developmental toxicology under REACH.

The European Union's REACH regulation has explicit requirements for reproductive and developmental toxicity data on all substances manufactured in or imported into the European Union at > or = 10 metric tons/year. Meeting the data requirements with whole-animal testing could result in the use of almost 22 million vertebrate animals for the registration of existing chemicals and cost up to several hundred thousand dollars per registered substance. The requirement for financial and animal resources can be reduced by the use of in vitro testing, quantitative structure-activity relationship models, and grouping of related substances. Although REACH strongly encourages these methods of avoiding vertebrate animal testing, it does not appear that in vitro testing or quantitative structure-activity relationship analysis will be able to replace whole-animal reproductive and developmental toxicity testing. Grouping of related compounds offers the possibility, perhaps in conjunction with in vitro testing and structure-activity analysis, of reducing vertebrate animal testing provided there is sufficient information on the related compounds and sufficient reason to believe that the related compounds will have similar toxicological properties. The designation of a substance as a reproductive or developmental toxicant follows criteria that do not consider the dose level of the substance at which reproductive or developmental effects occur, as long as excessive generalized toxicity does not occur. This method of labeling substances without consideration of effective dose level does not provide information on the actual risk of the chemical. Designation of a substance as a reproductive or developmental toxicant may have important implications under REACH and can be expected to result in the need to obtain authorization for marketing of the substance in the European Union.     

Perspectives on trace chemical safety and chemophobia: risk communication and risk management

Safety issues regarding consumer products contaminated with trace amounts of chemicals are of great concern to consumers, with the degree of concern occasionally escalating to the psychological syndrome, chemophobia, i.e., the fear of chemicals. Hazardous substances frequently implicated in safety concerns include heavy metals (arsenic, mercury, cadmium, and lead), volatile organic compounds (VOC) such as benzene and o-toluidine, pesticides, carcinogens, radioactive substances, and endocrine disrupting chemicals (EDC) such as bisphenol A and phthalates. To improve communication of risk to society, members of academia, government, consumer organizations, and industry participated in this workshop to discuss and exchange perspectives on trace chemical safety. From the perspective of academia, integrated risk assessments need to be implemented to encompass various exposure sources and routes. The identification and investigation of new exposure-related biomarkers are also recommended to verify direct causal relationships between specific chemical exposure and effects on human health. As for regulation, governments need to establish and maintain acceptable limits for trace chemicals in products. In addition, harmonized efforts need to be undertaken among government agencies to share regulatory limits and effectively control trace chemicals in consumer products. Manufacturers need to faithfully abide by Good Manufacturing Practice (GMP) guidelines, monitor sources of contamination, and minimize these for consumer safety. To effectively resolve safety issues arising from trace chemicals exposure, collaborative efforts are needed involving academia, government, consumer organizations, and industry. Further, scientific evidence-based risk assessment is a critical approach to effectively manage trace chemical safety issues.     

Concept of REACH and impact on evaluation of chemicals

Industrial chemicals have been in use for many decades and new products are regularly invented and introduced to the market. Also for decades, many different chemical laws have been introduced to regulate safe handling of chemicals in different use patterns. The patchwork of current regulation in the European Union is to be replaced by the new regulation on industrial chemical control, REACH. REACH stands for registration, evaluation, and authorization of chemicals. REACH entered force on June 1, 2007. REACH aims to overcome limitations in testing requirements of former regulation on industrial chemicals to enhance competitiveness and innovation with regard to manufacture safer substances and to promote the development of alternative testing methods. A main task of REACH is to address data gaps regarding the properties and uses of industrial chemicals. Producers, importers, and downstream users will have to compile and communicate standard information for all chemicals. Information sets to be prepared include safety data sheets (SDS), chemical safety reports (CSR), and chemical safety assessments (CSA). These are designed to guarantee adequate handling in the production chain, in transport and in use and to prevent the substances from being released to and distributed within the environment. Another important aim is to identify the most harmful chemicals and to set incentives to substitute them with safer alternatives. On one hand, REACH will have substantial impact on the basic understanding of the evaluation of chemicals. However, the toxicological sciences can also substantially influence the workability of REACH that supports the transformation of data to the information required to understand and manage acceptable and non acceptable risks in the use of industrial chemicals. The REACH regulation has been laid down in the main document and 17 Annexes of more than 849 pages. Even bigger technical guidance documents will follow and will inform about the rules for application and work out of dossiers. The following article gives a comprehensive overview on the concept of REACH to give deeper insight into this document. Members of the scientific community will have to define their own position as researchers, teachers, and experts to support the efforts to protect human health and the environment. The concept of REACH as well as new approaches to adapt standard testing regimes to foster a risk oriented approach in required work load to decrease animal based tests and to strengthen weight of evidence are explained in detail in this article.     

Perspectives on trace chemical safety and chemophobia: risk communication and risk management

Safety issues regarding consumer products contaminated with trace amounts of chemicals are of great concern to consumers, with the degree of concern occasionally escalating to the psychological syndrome, chemophobia (i.e., the fear of chemicals). Hazardous substances frequently implicated in safety concerns include heavy metals (arsenic, mercury, cadmium, and lead), volatile organic compounds (VOC) such as benzene and o-toluidine, pesticides, carcinogens, radioactive substances, and endocrine disrupting chemicals (EDC) such as bisphenol A and phthalates. To improve communication of risk to society, members of academia, government, consumer organizations, and industry participated in this workshop to discuss and exchange perspectives on trace chemical safety. From the perspective of academia, integrated risk assessments need to be implemented to encompass various exposure sources and routes. The identification and investigation of new exposure-related biomarkers are also recommended to verify direct causal relationships between specific chemical exposure and effects on human health. As for regulation, governments need to establish and maintain acceptable limits for trace chemicals in products. In addition, harmonized efforts need to be undertaken among government agencies to share regulatory limits and effectively control trace chemicals in consumer products. Manufacturers need to faithfully abide by Good Manufacturing Practice (GMP) guidelines, monitor sources of contamination, and minimize these for consumer safety. To effectively resolve safety issues arising from trace chemicals exposure, collaborative efforts are needed involving academia, government, consumer organizations, and industry. Further, scientific evidence-based risk assessment is a critical approach to effectively manage trace chemical safety issues.     

Exposure based waiving: The application of the toxicological threshold of concern (TTC) to inhalation exposure for aerosol ingredients in consumer products

The inhalation toxicology studies available in the public domain have been reviewed to establish a database for inhalation toxicology and derive thresholds of toxicological concern (TTC) for effects in the respiratory tract and systemically for Cramer class 1 and 3 chemicals. These TTCs can be used as the basis for developing an exposure based waiving (EBW) approach to evaluating the potential for adverse effects from exposure to ingredients in aerosol products, used by consumers. The measurement of consumer exposure in simulated product use is key to the application of an exposure based waiving approach to evaluating potential consumer risk. The detailed exposure evaluation for aerosol ingredients with defined use scenarios, in conjunction with an evaluation of the potential structure activity relationship for toxicity and the TTCs for inhalation exposure could be used to waive undertaking inhalation toxicology studies under REACH. Not all classes of chemicals are suitable for such an approach, but for chemicals with a predictable low potential toxicity, and very low levels of exposure, this approach, could reduce the amount of inhalation toxicology studies required for the implementation of the European REACH legislation. Such an approach is consistent with the concept of developing ‘intelligent testing strategies’ for REACH.     

Xenobiotic metabolism in human skin and 3D human skin reconstructs: a review

In this review, we discuss and compare studies of xenobiotic metabolism in both human skin and 3D human skin reconstructs. In comparison to the liver, the skin is a less studied organ in terms of characterising metabolic capability. While the skin forms the major protective barrier to environmental chemical exposure, it is also a potential target organ for adverse health effects. Occupational, accidental or intended-use exposure to toxic chemicals could result in acute or delayed injury to the skin (e.g. inflammation, allergy, cancer). Skin metabolism may play a role in the manifestation or amelioration of adverse effects via the topical route. Today, we have robust testing strategies to assess the potential for local skin toxicity of chemical exposure. Such methods (e.g. the local lymph node assay for assessing skin sensitisation; skin painting carcinogenicity studies) incorporate skin metabolism implicitly in the in vivo model system used. In light of recent European legislation (i.e. 7(th) Amendment to the Cosmetics Directive and Registration Evaluation and Authorisation of existing Chemicals (REACH)), non-animal approaches will be required to reduce and replace animal experiments for chemical risk assessment. It is expected that new models and approaches will need to account for skin metabolism explicitly, as the mechanisms of adverse effects in the skin are deconvoluted. 3D skin models have been proposed as a tool to use in new in vitro alternative approaches. In order to be able to use 3D skin models in this context, we need to understand their metabolic competency in relation to xenobiotic biotransformation and whether functional activity is representative of that seen in human skin.