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MERCURY 230<br />

2. HEALTH EFFECTS<br />

the MRL; that is, the relationship between inhaled concentration <strong>and</strong> target tissue concentration at the<br />

LOAEL <strong>and</strong> at lower levels (including the MRL) did not differ. There<strong>for</strong>e, exposure concentrations were<br />

used directly <strong>for</strong> the analysis. Gentry et al. (1998) also assumed that 1% of the unexposed population<br />

would be considered in the adverse response range. The BMD 10 was the dose at which the probability of<br />

exceeding the 1% adverse response level was 10% greater than in unexposed individuals, <strong>and</strong> the BMDL 10<br />

is the 95% lower bound confidence level on that dose. A simple linear model sufficed to describe the dose-<br />

response. A BMDL 10 of 0.017 mg metallic mercury/m 3 was derived as a reasonable representation of the<br />

sparse data. This level would be equivalent to a NOAEL (i.e., no LOAEL to NOAEL uncertainty factor is<br />

needed). Using a PBPK model to estimate target tissue doses from inhaled mercury vapor <strong>and</strong> adjusting <strong>for</strong><br />

continuous exposure <strong>and</strong> interhuman variability (with an uncertainty factor of 10), an MRL of<br />

0.0004 mg/m 3 (based on target tissue dose) was derived which is about two times the ATSDR derived MRL<br />

of 0.0002 mg/m3 based upon the Fawer et al. (1983) LOAEL.<br />

The ability of long-term, low-level exposure to metallic mercury to produce a degradation in neurological<br />

per<strong>for</strong>mance was also demonstrated in other studies. One such study (Ngim et al. 1992) attributed adverse<br />

neurological effects to a lower average level of exposure than did the Fawer et al. (1983) study; however,<br />

this study was not used in deriving a chronic inhalation MRL due to uncertainties concerning the study<br />

protocol, including methodological <strong>and</strong> reporting deficiencies. In the Ngim et al. (1992) study, dentists<br />

with an average of 5.5 years of exposure to low levels of metallic mercury were reported to have impaired<br />

per<strong>for</strong>mance on several neurobehavioral tests. Exposure levels measured at the time of the study ranged<br />

from 0.0007 to 0.042 mg/m 3 , with an average of 0.014 mg/m3 . Mean blood mercury levels among the<br />

dentists ranged from 0.6 to 57 µg/L, with a geometric mean of 9.8 µg/L. The per<strong>for</strong>mance of the dentists<br />

on finger tapping (measures digital motor speed), trail-making (measures visual scanning <strong>and</strong> motor speed),<br />

digit symbol (measures visuomotor coordination <strong>and</strong> concentration), digit span, logical memory delayed<br />

recall (measure of verbal memory), <strong>and</strong> Bender-Gestalt time (measures visual construction) tests was<br />

significantly poorer than controls. The exposed dentists also showed higher aggression than did controls.<br />

Furthermore, within the group of exposed dentists, significant differences were observed between a<br />

subgroup with high mercury exposure compared to a subgroup with lower exposure. These exposure<br />

severity subgroups were not compared to controls, <strong>and</strong> average exposure levels <strong>for</strong> the subgroups were not<br />

reported. The design <strong>and</strong> reporting of this study limits its usefulness in deriving an MRL <strong>for</strong> metallic<br />

mercury. The exposure status of the subjects was known to the investigator during testing, mercury levels<br />

were not reported <strong>for</strong> controls, <strong>and</strong> methods used to adjust <strong>for</strong> potential contributions other than mercury<br />

from amalgams to the study results (such as the possible use in this population of traditional medicines

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