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there was a slight increase in fibrosarcomas of the integumentary system, this was not considered by<br />

NTP to be a significant carcinogenic response. DMBA pretreatment had no additional effect.<br />

DHS staff members agreed with IARC (1982) that there is adequate evidence to support a conclusion<br />

that TCDD is carcinogenic to rats and mice and that TCDD should be considered a potential<br />

carcinogen to humans. The NTP bioassays (NTP 1980a) of HexaCDDs also indicated that the mixture<br />

used was tumorigenic.<br />

IV.<br />

DERIVATION OF CANCER POTENCY<br />

Basis for Cancer Potency<br />

Several human epidemiological studies of PCDD exposure reviewed in the dioxin TAC document<br />

(CDHS, 1986) reported results which suggested an increase in cancer incidence or mortality associated<br />

with PCDD exposure (Hardell and Sandstrom, 1979; Ericksson et al., 1981; Zack and Gaffey, 1983).<br />

However, these and the other studies described in the dioxin TAC document suffer from a number of<br />

limitations. The characterization of exposure to PCDD/PCDF were at best, uncertain. Usually the<br />

exposure occurred at a time when there were no sensitive measures of exposure levels. Exposure was<br />

often based on job title, self-reported use of substances which may have had PCDD contamination, or<br />

exposure to an event thought to have liberated PCDDs. Additionally, none of the human exposures<br />

described have been solely to PCDDs or PCDFs, but rather to a mixture of chemicals. PCDDs were<br />

only trace contaminants of other toxic chemicals. Many of the occupationally exposed subjects were<br />

exposed only briefly (e.g., during an accidental release), or worked in a possibly contaminated<br />

environment for a short time. For example, more than 75% of the workers studied by Ott et al. (1980)<br />

had been exposed for less than one year. Finally, many of the discussed studies, including the four US<br />

cohorts, have been hampered by small samples. Studies of only a few hundred subjects lack sufficient<br />

power to detect small increases in the risk of rare tumors. For these reasons, DHS staff members<br />

concluded that the epidemiologic data available at the time the dioxin TAC document was written<br />

provided insufficient in<strong>format</strong>ion to conclude whether or not PCDDs or PCDFs are human carcinogens.<br />

CDHS (1986) found that the most sensitive species, sex, and site for the induction of cancer by TCDD<br />

is the male mouse with hepatocellular adenomas or carcinomas (NTP, 1982a). This response is an<br />

order of magnitude greater than the least sensitive species, sex, and site examined, the female mouse<br />

subcutaneous fibromas. It is interesting to note that there is less than a four-fold difference in the unit<br />

risk between animal species for liver tumors. CDHS therefore developed an inhalation cancer unit risk<br />

value for TCDD based on the NTP (1982a) male mouse hepatocellular adenoma/carcinoma tumor<br />

data. CDHS also developed an inhalation cancer unit risk value for HexaCDD based on the most<br />

sensitive species, sex, and site for the induction of cancer. The data set chosen was the NTP (1980b)<br />

female rat liver neoplastic nodule or hepatocellular carcinoma incidence data as evaluated by<br />

Hildebrandt (1983).<br />

Methodology<br />

GLOBAL79 was used to fit a linearized multistage procedure to the NTP (1982a) male mouse<br />

179

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