Introduction
Statutorily, the Office of Environmental Health Hazard Assessment (OEHHA) is required to perform a risk assessment, and to develop and publish a public health goal (PHG), based exclusively on public health considerations, for contaminants that have, or are proposed to have, drinking water standards (maximum contaminant level, MCLs).
Statutorily, OEHHA bases PHGs exclusively on public health considerations, and uses current principles, practices, and methods of risk assessment, and currently available data. Furthermore, to the extent that scientific data are available, the PHG is to take into account synergistic effects, effects of the contaminant on sensitive subgroups (including infants, children, pregnant women, individuals with a history of serious illness, and other subpopulations that are at a greater risk), and additive effects of the contaminant in media other than drinking water. If adequate scientific evidence is available, a threshold may be identified.
Statutorily,
MCLs for drinking water contaminants are adopted as regulations by the
Department of Health Services (DHS).
An MCL for a contaminant is required to be established at a level that
is as close as technologically and economically feasible to the corresponding
PHG, placing primary emphasis on the protection of public health.
DHS,
in its regulatory capacity, serves as the risk manager for contaminants in
drinking water, while OEHHA is the risk assessor.
One
contaminant for which DHS plans to adopt an MCL is chromium-6. (Chromium-6 is currently regulated as
total chromium, a combination of chromium-3 and chromium-6.) Consistent with the provisions of the
Statute, OEHHA will be developing a PHG for chromium-6, which may include an
evaluation of the carcinogenic risk of the chemical.
The
purpose of the Committee is to present written recommendations, and their
scientific basis, to the Director of OEHHA, on the questions below regarding
the potential carcinogenic risks of chromium-6 in drinking water, based on an
evaluation of the scientific literature and exclusively
on public health considerations as described in the introduction. OEHHA will consider these
recommendations in developing a chromium-6 PHG.
The
Evaluation Will Focus on the Following Questions:
1)
Considering the
toxicology, epidemiology and mechanistic information available regarding
chromium-6, should chromium-6 be considered as posing a carcinogenic risk by
the oral route?
2)
If chromium-6 is to be
considered as posing a carcinogenic risk by the oral route, what approaches
does the Committee suggest to establish a PHG?
·
The Borneff et al.,
(1968) mouse study is the only animal drinking water study of which we are aware that
was designed to look at the potential carcinogenic effects of chromium-6. We are seeking your comments on the
strengths and weaknesses of this study for purposes of making a quantitative
estimate of the cancer risk for chromium-6 in humans.
·
Does the epidemiology
literature contain studies that would be useful to derive a cancer potency for
chromium-6, such as, using the occupational data reporting excess
gastrointestinal or other non-respiratory tumors?
·
If the available literature does not
allow the development of a cancer potency factor, what studies are available
that would allow the development of a PHG that could take into account
potential cancer risks from chromium-6.
For example, some agencies apply an additional safety factor to the
non-cancer chronic health effects observed in animals.
3)
The conversion of
chromium-6 to chromium-3 by simple chemical reactions in the stomach and
pharmacokinetics after absorption can influence the toxic effects of
chromium-6.
·
How can the effects be
quantified and the results applied as part of the approach in developing a
PHG? As
examples:
(1)
Change the
slope of the dose-response curve;
(2)
Change the
shape of the dose-response curve.
·
Is there literature
that indicates variability in the general population in the conversion of
chromium-6 to chromium-3?
·
Is there adequate information
to identify a threshold for the oral route of exposure?