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The Toxicologist - Society of Toxicology

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1525 SAFETY ASSESSMENT OF FOOD AND FEED FROM<br />

BIOTECHNOLOGY-DERIVED CROPS WITH<br />

MODIFICATIONS THAT REGULATE ENDOGENOUS<br />

GENE EXPRESSION.<br />

J. S. Petrick 1 , W. Parrott 2 , B. Chassy 3 , J. Ligon 4 , L. Meyer 5 , J. Zhou 6 , R.<br />

Herman 7 , B. Delaney 8 and M. Levine 9 . 1 Product Safety Center, Monsanto<br />

Company, Saint Louis, MO, 2 Crop and Soil Sciences, University <strong>of</strong> Georgia, Athens,<br />

GA, 3 College <strong>of</strong> ACES, University <strong>of</strong> Illinois, Urbana, IL, 4 Bayer CropScience,<br />

Research Triangle Park, NC, 5 Syngenta Biotechnology, Inc., Research Triangle Park,<br />

NC, 6 Johnson & Johnson, Raritan, NJ, 7 Dow AgroSciences, Indianapolis, IN,<br />

8 Pioneer, A DuPont Company, Johnston, IA and 9 International Life Sciences Institute,<br />

Washington, DC.<br />

Agricultural biotechnology traits in development include those using tools such as<br />

transcription factors and RNA interference (RNAi) to modulate endogenous plant<br />

gene expression for the improvement <strong>of</strong> yields, tolerance to biotic and abiotic<br />

stresses, and nutritional quality. Biotechnology-derived crops are presently evaluated<br />

for food and feed safety relative to a conventional comparator according to an<br />

internationally-accepted safety assessment paradigm. This robust and comprehensive<br />

approach incorporates basic concepts from food safety, toxicology, nutrition,<br />

molecular biology, and plant breeding and has been used effectively by scientists<br />

and regulatory agencies for nearly 15 years. <strong>The</strong> main aspects <strong>of</strong> the comparative<br />

safety assessment process are reviewed and recommendations are provided for scientifically<br />

sound principles to evaluate the safety <strong>of</strong> biotechnology-derived crops<br />

developed using biological approaches that modify endogenous plant gene expression.<br />

Key considerations for applicability <strong>of</strong> the existing safety assessment process<br />

include: 1) <strong>The</strong> history <strong>of</strong> safe consumption <strong>of</strong> RNAi- mediating small RNAs (e.g.,<br />

miRNAs) and regulatory proteins such as transcription factors; 2) <strong>The</strong> growing scientific<br />

literature describing the central role that RNAi and transcription factors<br />

have played in plant domestication and conventional breeding; 3) Crops engineered<br />

using RNAi constructs are not expected to produce heterologous proteins;<br />

4) Modulation <strong>of</strong> plant gene expression may result in quantitative differences in<br />

levels <strong>of</strong> endogenous plant components (but not de novo components) that can be<br />

assessed through compositional analysis.<br />

1526 USE OF CLUSTER ANALYSIS IN PESTICIDE INERT<br />

INGREDIENT RISK ASSESSMENT.<br />

A. S. Duggan 1 , J. Johnston 2 , J. Messina 2 , K. Akkari 3 , D. Hillebold 4 , G.<br />

Lindner 5 and P. McCain 6 . 1 Health Practice Center for <strong>Toxicology</strong> and Mechanistic<br />

Biology, Exponent, Inc., Philadelphia, PA, 2 Health Practice Center for Chemical<br />

Regulation and Food Safety, Exponent, Inc., Washington, DC, 3 APD/RD, BASF<br />

Corp., Research Triangle Park, NC, 4 Surface Chemistry, Akzo Nobel, LLC, Chicago,<br />

IL, 5 Crop Care Applications, Croda, Inc., New Castle, DE and 6 Regulatory Affairs,<br />

Syngenta Crop Protection, Inc., Greensboro, NC.<br />

<strong>The</strong> poster illustrates the use <strong>of</strong> read-across methodology and dietary risk assessment<br />

for oleochemical surfactants that are used as inert ingredients in pesticide formulations.<br />

<strong>The</strong> August 9, 2006, revocation <strong>of</strong> 130 food tolerance exemptions resulted in<br />

unprecedented challenges for EPA and industry (pesticide registrants and surfactant<br />

manufacturers) to evaluate reproductive and developmental toxicity for more than<br />

20 classes <strong>of</strong> inert ingredients within three years. Structurally similar compounds<br />

have similar physical, metabolic and toxicological properties. It is possible to bridge<br />

(read-across) results from one compound to others within a defined cluster <strong>of</strong> chemically-related<br />

compounds. EPA and the OECD applied cluster analysis in the High<br />

Production Volume (HPV) Programs to reduce the number <strong>of</strong> toxicity tests, laboratory<br />

animals and the time required to review the study data. <strong>The</strong> same methodology<br />

was successfully used to conduct OECD 422 Studies (Combined Repeated Dose<br />

Toxicity Study with the Reproduction/Developmental Toxicity Screening Tests)<br />

data development plans. <strong>The</strong> OECD 422 test results were used in conjunction with<br />

the EPA screening-level dietary exposure model for inert ingredients (I-DEEM) to<br />

assess dietary exposure and risks for the US population, adults and children. <strong>The</strong><br />

methodology was validated and resulted in the successful reassessment and retention<br />

<strong>of</strong> the food use tolerance exemptions <strong>of</strong> the inert ingredients.<br />

1527 OPTIONS FOR INCREASED REGULATORY<br />

OVERSIGHT OF COSMETICS IN THE U.S.<br />

N. Beck 1 , K. Sullivan 1 and C. Willet 2 . 1 Physicians Committee for Responsible<br />

Medicine, Washington, DC and 2 People for the Ethical Treatment <strong>of</strong> Animals,<br />

Norfolk, VA.<br />

Cosmetics have recently become one <strong>of</strong> the focal points <strong>of</strong> efforts to strengthen<br />

chemical regulations in the US. Under the current law, cosmetics manufacturers are<br />

responsible for substantiating the safety <strong>of</strong> their products, but for most ingredients,<br />

328 SOT 2011 ANNUAL MEETING<br />

specific toxicity testing is not required, nor is pre-market approval from the Food<br />

and Drug Administration (FDA). Concern over the long-term safety <strong>of</strong> cosmetics<br />

has prompted legislative efforts to increase oversight. Emerging regulatory models<br />

in the US were analyzed, namely the “FDA Globalization Act <strong>of</strong> 2009” and the<br />

“Safe Cosmetics Act <strong>of</strong> 2010.” Specifically, each bill’s approach to hazard and risk<br />

assessment, was examined, including their flexibility in information requirements<br />

and potential for incorporating evolving science. <strong>The</strong>n, current US cosmetics regulations<br />

were compared with international approaches, revealing broad agreement<br />

overall. Finally, the proposed US models were addressed in the context <strong>of</strong> the EU’s<br />

distinctive position on animal testing. EU law gradually phases out the use <strong>of</strong> animals<br />

for cosmetics testing, with a complete ban on the marketing <strong>of</strong> animal-tested<br />

products by 2013. <strong>The</strong> market ban presents significant implications for trade with<br />

the EU, which should be considered when drafting new legislation in the US. <strong>The</strong><br />

testing and marketing prohibitions in the EU have also impacted the state <strong>of</strong> regulatory<br />

toxicology, with the impending ban serving as a tool to drive progress in the<br />

development <strong>of</strong> in vitro and in silico test methods. In order to efficiently assess cosmetic<br />

ingredients and advance international harmonization, proposals to reform<br />

US cosmetics regulations should seek to facilitate the development <strong>of</strong> modern, harmonized<br />

approaches to testing and assessment.<br />

1528 THE SHE CELL TRANSFORMATION ASSAY—ITS USE<br />

IN HAZARD AND RISK ASSESSMENT FOR REACH.<br />

A. H. Poth. Genetic and Alternative <strong>Toxicology</strong>, Harlan Cytotest Cell Research<br />

GmbH, Rossdorf, Germany.<br />

<strong>The</strong> 2-year bioassay is the standard method for carcinogen detection which is time<br />

and resource intensive. Many short-term test, especially genotoxicity tests have<br />

been developed to aid in identification <strong>of</strong> potential carcinogens. However, the endpoint<br />

<strong>of</strong> theses systems is genotoxicity and their concordance between rodent bioassays<br />

is only about 60% and a battery <strong>of</strong> short-term genotoxicity tests can not improve<br />

the overall concordance. In vitro cell transformation tests using SHE- and<br />

Balb/c3T3-cells simulate the process <strong>of</strong> animal two-stage carcinogenesis. <strong>The</strong>se tests<br />

are suited for the in vitro detection <strong>of</strong> a carcinogenic potential <strong>of</strong> test compounds in<br />

safety and risk assessment. Results from cell transformation assays can provide information,<br />

which in combination with data from other testing methods, are useful<br />

for identifying the carcinogenic potential <strong>of</strong> chemical compounds. <strong>The</strong> results <strong>of</strong><br />

these assays in combination with other information such as genotoxicity data,<br />

structure activity analysis, in vivo toxicity data and pharmaco-/toxicokinetic information<br />

can facilitate a relatively comprehensive assessment <strong>of</strong> a carcinogenic potential<br />

<strong>of</strong> a chemical. For prediction <strong>of</strong> the carcinogenic potential <strong>of</strong> compound the<br />

SHE cell transformation assay is included in the endpoint specific guidance document<br />

for REACH. In the first phase <strong>of</strong> REACH (substances > 1000 tonnage per<br />

year), data <strong>of</strong> the SHE cell transformation were included in the hazard and risk assessment.<br />

Case studies are provided for heavy metal powders and alloys, where the<br />

SHE cell transformation data were used for mechanistic investigations beside other<br />

in vitro test systems. SHE cell transformation data are also provided <strong>of</strong> a chemical<br />

class (aromatic amines) where genotoxicity data do have only limited value and for<br />

a compound with an structural alert for carcinogenicity (pararosaniline derivatives),<br />

where SHE cell transformation data were used to demonstrate the similarities<br />

across a chemical category.<br />

1529 DEVELOPMENT OF A HEALTH RISK-BASED SURFACE<br />

CONTAMINATION CLEAN-UP STANDARD FOR<br />

OCCUPATIONAL EXPOSURE TO BERYLLIUM.<br />

P. Damian. SCS Engineers, West Sacramento, CA.<br />

A health risk-based surface contamination cleanup standard (SCS) for beryllium<br />

(BE) was developed to facilitate the safe transfer <strong>of</strong> property (equipment and buildings)<br />

previously used in BE-related processes. Previous SCSs for BE were primarily<br />

based on Department <strong>of</strong> Energy (DOE) housekeeping criteria rather than health<br />

risks. Quantitative health risk assessment methods were used to develop an occupational<br />

SCS that explicitly considers the relevant exposure pathways and toxicity<br />

endpoints, including both cancer and non-cancer endpoints. For the cancer endpoint<br />

at the 1E-06 risk level, the analysis resulted in an SCS <strong>of</strong> 17 μg/100 cm 2<br />

based on resuspension <strong>of</strong> settled dust and subsequent inhalation exposure only (BE<br />

is regulated as a carcinogen by the inhalation route only). For the non-cancer endpoint,<br />

the analysis resulted in an SCS <strong>of</strong> 0.07 μg/100 cm 2 based on dermal absorption,<br />

incidental ingestion following dermal contact, and inhalation. <strong>The</strong> non-cancer<br />

SCS was determined virtually entirely by the dermal absorption exposure<br />

pathway, with negligible contributions from the incidental ingestion and inhalation<br />

pathways. This analysis shows that application <strong>of</strong> the non-cancer SCS in BE monitoring<br />

and control programs will adequately protect workers from both the cancer<br />

and non-cancer health effects <strong>of</strong> BE when surface contamination is the primary<br />

source <strong>of</strong> BE exposure.

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