(VCCEP) Tier 1 Pilot Submission for BENZENE - Tera

in significant reductions in benzene emissions and exposure levels over the past decades (see
Sections 5 and 7).
This downward exposure trend will continue as new programs and regulations are implemented.
EPA has estimated that over 70% of ambient benzene exposure is from mobile sources, both
gasoline emissions and combustion exhaust (see Section 7). As noted in Section 4, EPA has an
ongoing mobile source rulemaking that targets benzene as a toxic of concern. This rulemaking
will be completed long before a 2-generation reproduction study could be completed.
Finally, when the OECD (including the U.S. EPA) reviewed benzene in October 2005, it
concluded that “further testing is not warranted” on benzene reproductive effects. Virtually all
existing risk assessments and risk management actions for benzene are based on human data.
For all of these reasons, the Consortium does not believe there is adequate rationale or
justification to conduct a 2-generation reproduction study in experimental animals on benzene.
9.2 Exposure
For compounds, like benzene, that occur in many environments, additional exposure
assessment work is always possible. The VCCEP sponsors believe, however, that the
information presented in the Exposure Assessment (Section 7) is fully adequate to demonstrate
exposures to benzene from anticipated sources. Benzene exposures have been declining for
many years due to extensive environmental regulations (see Section 4), gasoline and product
reformulations, emission control improvements for cars and trucks, smoking limitations in public
buildings, and other factors. This downward exposure trend for benzene will continue with the
introduction of additional regulations and controls, as such future exposure data will likely be
lower then the data presented in this assessment.
Benzene VCCEP Submission 196
March 2006