Risk Assessment in Toxicology
Risk Assessment in Toxicology
Risk Assessment in Toxicology
Toxicology Consultants & Assessment Specialists, LLC
FORENSIC TOXICOLOGY ENVIRONMENTAL TESTING TOXIC EXPOSURES RISK ASSESSMENT CAUSATION EVALUATION
Risk Assessment in Toxicology
Risk assessment is a multistep process which, in conjunction with an exposure assessment and other components, produces estimates of
risk of an adverse health effect occuring as a consequence of ingesting, inhaling and/or absorbing one or more toxic substances. TCAS has
produced many risk assessments over a period of more than 28 years (additional information can be found in our case studies).
Toxicological Risk Assessment Components
In an exposure scenario, the expert toxicologist's role is
primarily to address "baseline risk." The illustration at right
outlines the components of a baseline risk assessment.
This is an analysis of potential adverse health effects
(current or future) caused by the release of a toxic
substance prior to remediation.
1. Data Collection and Evaluation
Data collection and evaluation is the process of gathering
and analyzing site data. It may also involve compilation of
geophysical data and historical information relevant to the
release of toxic agent(s). The expert toxicologist must
identify the substances of potential significance present at
the site, as these will be the focus of the risk assessment
process.
2. Exposure Assessment
An exposure assessment estimates the magnitude,
frequency and duration of human exposures. It also
defines the pathways by which humans are potentially
exposed. The results of an exposure assessment are a
set of pathwayspecific doses (or inhalation levels) for
current and future exposures to the substance(s) at issue.
Adapted from U.S. EPA: Risk Assessment Guidance for Superfund. [a]
1. Hazard identification essentially consists of research based on chemicalspecific toxicity studies and the prevailing body of generally
recognized, peerreviewed literature. The expert toxicologist assesses the nature and strength of causative evidence to determine if a
particular substance is capable of causing specific adverse health effects.
2. The doseresponse evaluation quantitatively evaluates the toxicity relationship between dose and incidence of adverse health effects.
From this the expert toxicologist derives toxicity values which are subsequently used to assess the potential incidence of adverse
health effects at different exposure levels.
4. Risk Characterization
Risk characterization combines and summarizes the exposure and toxicity assessments to produce baseline risk estimates. To produce a
reliable baseline risk assessment, the toxicologist must essentially compile a concise history of toxic release events and exposures from a
toxicological perspective. Typically, the expert toxicologist presents his findings in both quantitative and qualitative statements in the form of
a written report. The report must disclose all findings and, in particular, must credibly compare chemicalspecific toxicity data against
measured contaminant exposure dose levels and exposure duration. The report also must estimate risk based on fate and transport
modeling to determine whether current and future exposure levels may be of potential concern (based on the prevailing landuse
assumptions).
Risk Assessment Methodology
A "methodology" (or unified set of methods) provides principles, rules and guidance for producing results consistent with the application of
specific investigative procedures. It is important to keep in mind that the primary focus of a toxicological risk assessment is human health. In
keeping with this mandate, the expert toxicologist must apply a specific set of methods to conduct a reliable risk assessment. The U.S. EPA
publishes indepth risk assessment guidance 1 and this methodology serves as the procedural basis for most risk assessments in the U.S.
Procedural guidance is extremely useful in an evidential investigation. However, objective scientific judgment also plays an important role.
Only by strict attention to detail can scientifically credible findings be produced. All toxicological conclusions must meet the criteria for
reasonable toxicological certainty. Thus, in the course of producing a credible risk assessment, a number of potentially pivotal issues may
arise which, if not addressed in accordance with the generallyaccepted methodology, could lead to a report being challenged. The following
paragraphs summarize some of these issues.
Scientific Credibility
The spirit of any risk assessment is to completely and factually provide full disclosure of all relevant factors in a contamination scenario by
applying generallyaccepted, peerreviewed methods. Thus, selection of assessment method is just as important as carrying out the
analysis itself. The choice of method has the potential not only to impact the results of a risk assessment but can also impact the scientific
credibility of the report. The expert toxicologist must, therefore, ensure that all assessment methods are appropriate and consistent with the
objectives of accuracy and reliability.
For example, in most sitespecific assessments, it is critically important to identify and delineate locations which still contain residual
contamination. These are typically designated as Areas of Concern (AOCs). Within each AOC, there may be several Areas of Investigation
(AOIs) which delineate areas containing known contaminant concentrations.
Areas of Concern (AOCs) are regions in which contaminants have been released to the environment or a waste management unit.
When one or more chemicals are released into the environment, a responsible assessment must do more than report average
contamination levels spread over a broad region. The assessment must also establish the boundaries of impacted areas (typically
delineated horizontally and vertically). Since contamination can impact future land use and the surrounding community, successful
remediation relies on correctly identifying contaminated areas and addressing them in compliance with regulatory guidance.
Areas of Investigation (AOIs) represent zones within an Area of Concern (AOC) in which measured chemical concentrations
(through sampling or monitoring) can be shown to exceed regulatory standards.
Areas of investigation are important because they identify and isolate specific chemical concentrations. This has a relevant bearing on risk
assessment. Failing to identify AOIs in the exposure region can lead to erroneous and misleading results. In the illustrations below (from an
actual TCAS case), samples were taken in a residential area to determine the extent of contamination.
In this example, samples which exceed regulatory limits were identified In this example, levels exceeding regulatory limits were not identified and
within each AOI. It is thus possible to calculate the 95% UCLAM (95 thus AOIs were not defined. Averaging samples together merely dilutes the
percent upper confidence limit of the arithmetic mean) for each AOI. This overall mean, producing erroneous and misleading results. This method is
method is valid for risk assessment and helpful for remediation. [b] useless for either risk assessment or remediation. [c]
In the first example, areas of investigation were defined and the results compiled in a manner consistent with the spirit of the risk
assessment; i.e. a calculation of the 95% UCLAM (95 percent upper confidence limit of the arithmetic mean). This allows for correlation
with cancer risk, slope factors, hazard index and regulatory standards. This calculation is performed for each substance in every AOI in
which substance concentrations exceed regulatory levels. This is a valid method because it is in every way consistent with prevailing
Federal and State risk assessment guidance (i.e. U.S. EPA, RAGS, RECAP, etc.).
In the second example, no individual areas of investigation (AOIs) were defined. The assessment merely averaged all of the samples
together. Diluted averages present an unreliable assessment of localized concentrations. The underlying assumption that diluted averages
quantitatively represent AOIs under consideration for remediation is erroneous. This approach invariably produces misleading results and is
valid only in cases where no regulatory exceedances are present in the sample data.
Cancer Risk Calculations
Cancer risk determinations are a key part of risk characterization. U.S. EPA publishes detailed "Guidelines for Carcinogen Risk
Assessment." 2 However, the expert toxicologist must also consider additional guidance documents and utilize the most recentlyavailable
information on target organ effects when assessing cancer risks. New guidance is continually being published as new peerreviewed studies
become part of the evergrowing body of toxicological literature. The expert toxicologist should always address such guidance to ensure that
information from studies on carcinogenesis and other health effects are considered together in the overall characterization of risk.
The expert toxicologist must be consistent in presenting cancer risk conclusions. Cancer slope factors convert estimated daily intakes
averaged over a lifetime of exposure directly to an incremental risk of a person developing cancer. As a general rule, average lifetime
exposures should be used while all lessthanlifetime exposures should be converted to equivalent lifetime values. Similarly, if a toxicity
value is based on average lifetime exposure (e.g., slope factors), then the exposure duration should be expressed in the same manner.
Thus, it is important to remember that the variables in both the exposure assessment and the toxicity assessment should all be based on
the same underlying set of conversion factors.
Although the approach for estimating carcinogenic risk is based on the assumption that a high dose received over a short period of time is
equivalent to a corresponding low dose spread over a lifetime, this approach becomes problematic as the exposures in question become
more intense but less frequent. This is especially true for confirmed human carcinogens and/or when there is evidence that the agent has
shown doserelated carcinogenic effects. Therefore, the expert toxicologist may need to assess the level of uncertainty associated with the
exposure assessment for carcinogens. Both U.S. EPA and WHO 3 recommend that "...the discussion of uncertainty should be included in
both the exposure assessment and risk characterization chapters of the risk assessment report."
Assumptions
For risk assessment purposes, it can generally be assumed that the doseresponse relationship will be linear in the lowdose portion of the
multistage model doseresponse curve. U.S. EPA has stated that relatively low intakes (compared to those experienced by test animals)
tend to originate mainly from environmental exposures. However, these assumptions may not hold true for all cases, particularly those
involving shortterm or higherdose exposures. Regulatory guidance on these topics is continually being updated. The expert toxicologist
should always review the most recent guidance before settling upon a particular method for performing cancer risk calculations.
Although U.S. EPA publishes detailed information concerning "default" intake values for a wide variety of circumstances, age groups, etc.,
some states have legislated their own corrective action policies. Some of these policies provide specific guidelines for exposure intake
levels. For example, a person living in a coastal region may consume greater quantities of shellfish than a person living in a landlocked
state. In such cases, certain "default" assumptions may exist with respect to intake values. These may be further qualified by land use
(whether an area is classified for residential use, industrial use, etc.). In such cases, the expert toxicologist will generally apply the default
assumptions unless there are compelling reasons to do otherwise. Additionally, the land use assumptions and source of intake values
applied in risk calculations must always be clearly defined as these serve to codify and validate regionspecific baseline risk conclusions.
Historical Factors
It is important to bring historical factors to the forefront in a risk assessment. Historical factors may have a direct and relevant bearing on
remediation in a toxic release scenario particularly in cases of chronic longterm exposures. For example, if laboratory results of soil or
water samples taken prior to a release are available, comparison of these samples with more recent samples may have a direct bearing on
assessing risk. Such data can be used to demonstrate concentration decreases or increases over time. Such data may also subsequently
prove to be evidential if applying Hill Factors in a causative investigation.
Standards of Admissibility
Risk assessment testimony is governed by the same rules of evidence as causation and other scientific aspects of toxicology. In particular,
toxicological testimony cannot be considered admissible if the evidence is based upon a "novel" scientific technique or methodology. Expert
testimony must have its basis in reliable scientific techniques which are generally accepted by the relevant scientific community. The expert
toxicologist's testimony must be responsive to answering the questions at issue and rest on a sound, reliable scientific foundation (Rule 702,
Federal Rules of Evidence). 4 Although personal observations and professional experience may contribute to formulating an opinion, they do
not in themselves constitute an admissible basis for a conclusion and, if offered, must be supported by "good science."
Medical Monitoring
In conjunction with risk assessment, exposure assessments indicative of significant human health risks can trigger the need for medical
monitoring. Medical monitoring is defined in legislation as "...periodic medical testing to screen people at significant increased risk for
disease." This is a specific set of procedures 5 defined by the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) or more commonly known as "Superfund." The specific objective of Superfund is "...to clean up uncontrolled releases of specified
hazardous substances."
In the context of toxicology, risk assessment is recognized under the CERCLA statutes in that environmental testing may serve as a marker
for exposure based on risk. ATSDR (the Agency for Toxic Substances and Disease Registry) has established criteria to determine when
medical monitoring is an appropriate health activity and the requirements for establishing a medical monitoring program at a site:
"The primary criteria for medical monitoring should be documented evidence of exposure of a population to a hazardous substance
in the environment. An exposure will be considered to be at a sufficient level if there is documentation of an increased opportunity
for exposure to a level that meets or exceeds some healthbased comparison value, such as Minimum Risk Levels (MRLs) or
Reference Doses (RfDs), or that meets or exceeds a level reported in the peerreviewed literature to result in some adverse health
effect. Documentation is considered sufficient if it is from an exposure assessment, environmental exposure modeling, or sampling
from a general area (for example, water samples from an aquifer or a town water supply). Documentation of individual levels of
exposure is not required. In cases in which exposures are unknown or undocumented, environmental monitoring is a more
appropriate initial activity."
"In areas where biological markers of exposure have not been collected, environmental sampling can be used to estimate exposure
levels. The target population of concern is the population in which there is documented exposure at a sufficient level to place the
individuals in that population at significant increased risk for developing some specific adverse health effect."
"ATSDR's Final Criteria for Determining the Appropriateness of a Medical Monitoring Program Under CERCLA," 1995 Jul 28;60 FR 3884044.
Medical monitoring is typically directed toward a target community identified as being at "significant increased risk for disease" on the basis
of its exposure. This can involve small numbers of people or tens of thousands. Significant increased risk will vary from site to site
depending upon such factors as the potential magnitude of harm of the specific outcome, the risk attributable to the exposure or the
presence of sensitive subpopulations.
Medical monitoring can be expensive and is frequently a matter of significant concern in litigation. An experienced, objective toxicological
assessment to determine if there is a bona fide need for medical monitoring in compliance with the CERCLA criteria is an absolutely
essential component in environmental cases involving a community or class of individuals.
Summary
A wellorganized toxicological risk assessment reliably measures the likelihood of adverse human health effects from a potential toxic
exposure. It can also offer guidance with respect to property remediation, disposition and futureuse issues. The expert toxicologist must
pragmatically research contributing and historical factors, perform the required dose and risk calculations in the proper order, professionally
summarize the results and communicate written findings in a scientificallyobjective manner.
The benefits of an objective risk assessment produced in accordance with generallyaccepted guidelines (such as those published by U.S.
EPA) are many. Aside from accurately characterizing potential risk of adverse health effects, a wellconstructed risk assessment can be
instrumental in assisting a judge and jury when making decisions pertaining to remediation, medical monitoring, environmental monitoring,
administration and other matters at issue.
Notes and References
1. U.S. Environmental Protection Agency, "Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual,"
2. U.S. Environmental Protection Agency, "Guidelines for Carcinogen Risk Assessment
3. World Health Organization, "Principles and Methods for the Risk Assessment of Chemicals in Food,"
4. Federal Rules of Evidence, "Rule 702. Testimony by Expert Witnesses," Cornell University Law School, 2011
5. Agency for Toxic Substances and Disease Registry, "ATSDR's Final Criteria for Determining the Appropriateness of a Medical Monitoring Program Under
CERCLA," Federal Register, 1995 Jul 28;60 FR 3884044.
Images
a. Graphical image adapted from U.S. EPA, "Risk Assessment Guidance for Superfund,"
b. TCAS report demonstrative (redacted), graphical image © Copyright 2017 TCAS, LLC.
c. TCAS report demonstrative (redacted), graphical image © Copyright 2017 TCAS, LLC.
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