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(CASAC) Peer Review of EPA's Integrated Science Assessment

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17. The complexity <strong>of</strong> the curve in Figure 4-5 is intriguing, as we find the same thing inradiation dose-response curves. It usually occurs when there are competing beneficial anddetrimental effects at low exposures, due to compensatory mechanisms kicking in.18. On pages 4-9 and 4-10, a susceptible subpopulation is defined as one that mightshow effects below concentrations needed in the general population. This is much toovague <strong>of</strong> a statement, as it applies to any individual whose individual threshold is belowthe population median (50% <strong>of</strong> the population therefore being susceptible). And again,there IS no general population response, only the aggregate response <strong>of</strong> individuals with adistribution <strong>of</strong> thresholds. Better definitions <strong>of</strong> susceptible and sensitive are needed, onesrelated in some way to percentiles <strong>of</strong> the intersubject variability distributions and somenotion <strong>of</strong> biomodality <strong>of</strong> these distributions.Based on Comments 12-18, I judge that Chapter 4 is better overall than the previousdraft, and is nicely organized for the kinds <strong>of</strong> information presented. But I continue tohave problems with the way in which public health impact is quantified. I don’t believethis chapter provides quantitative information on actual impacts, but rather thePOTENTIAL for impacts if exposures are sufficient.19. Figure 4-6 suffers from having a wide range <strong>of</strong> ages in the young group (0-14 years).Is there no way to narrow in on the much younger ages where sensitivity seemsespecially pronounced?The following comments apply to Charge Question 5:20. Chapter 5 continues the pattern <strong>of</strong> having little formal framework for integratinginformation. The EPA seems to cite a different source for frameworks in each ISA (hereit is the NAS Institute <strong>of</strong> Medicine Report). I don’t have an alternative to <strong>of</strong>fer, so justbelieve it would be best if the authors just state the principles they are using directly andnot rely on a particular source (requiring the reader to go back to those sources forclarification).21. On page 5-2, line 20, a causal relationship is inferred (reasonably), but needs to beaccompanied by a statement <strong>of</strong> the levels <strong>of</strong> exposure at which the relationship applies.The existing statement is too broad. There are causal relationships between exposure andadverse effect for all things in the world, at some level <strong>of</strong> exposure.22. The discussion <strong>of</strong> uncertainty throughout is inadequate. It could lifted out <strong>of</strong> here andplaced down into any <strong>of</strong> NAAQS ISAs, it is so generic. There needs to be a bettersummary <strong>of</strong> the uncertainty and its implications for specific judgments that might berequired in exposure and risk assessments.Overall, Chapter 5 provides a good compendium <strong>of</strong> information that should prove usefulfor the exposure and risk assessment stages. It adequately summarizes causal claims,although I don’t believe it properly places caveats with respect to the exposure levels atwhich these causal claims are strong.12

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