(VCCEP) Tier 1 Pilot Submission for BENZENE - Tera

the continental U.S. for each leukemia subtype. In the 1997 report, the cancer incidence for
leukemias were broken into subtypes of origin of cell-line (myeloid, lymphocytic, monocytic,
other) but did not differentiate between acute or chronic. The incidence of myeloid leukemias in
1997 in Alaska was 3.9 per 100,000 (95% CI: 2.2 - 6.6) and the US rate for the years 1993-1997
was reported as 4.4 per 100,000 (Alaska 2000a), suggesting no significant difference between
the two. The report for the 1998 cancer registry provided more refined disease classification
which allowed for a comparison of specifically AML, the disease of concern with benzene. The
incidence of AML in 1998 in Alaska was 3.3 per 100,000 (95% CI: 1.7 – 5.9) and 2.8 in the U.S.
for the years 1994 – 1998, again demonstrating no difference between the incidence of AML in
Alaska and the U.S. There appears to be no difference in the incidence of leukemia (the
subtypes of leukemia were not broken out in the Alaska report) between whites and Alaska
natives (Alaska 2000b). AML incidence data for Alaska is not consistent with the hypothesis
that Alaskan children are at higher risk due to increased benzene exposure.
As previously discussed, available epidemiological data strongly support that a threshold exists
for benzene’s hematopoietic toxicity, including the risk for developing AML. While the actual
exposure/dose required for the development of AML is not universally agreed upon, the
existence of a threshold for AML is consistent with clinical data obtained from secondary
leukemia arising from ionizing radiation and/or chemotherapy and our current understanding of
bone marrow patho-physiology and biology. For this reason, the cancer risk associated with
benzene exposure was calculated with a MOS approach, predicated on a non-linear dose
response relationship for the induction of AML. Additionally, clinical data on leukemia risk
associated with the treatment of primary pediatric cancers do not support the hypothesis that
children are at increased risk of developing chemically induced AML. As a result, a threshold
for the development of AML in adults would likely be the same in children. Moreover, published
data on the myelosuppressive/hematotoxic effects of various chemotherapy agents in children
and adults do not support the existence of an age related difference in sensitivity. Therefore,
additional uncertainty factors were not deemed necessary to adequately assess the risk of
benzene associated adverse health effects in children.
Levels of benzene in the ambient environment have declined substantially over the past four
decades and are anticipated to continue to decline. Therefore, the estimated margins of safety
are anticipated to increase over the coming years and decades.
Benzene VCCEP Submission 194
March 2006