Fair comments, however discussing synergistic
effects when we can't even agree as nation on the effects of the individual
compounds could be a difficult and the interpretation of this approach
will be open to challenge. I think it would be an uncomfortable decision
to determine a site on this basis or ask for works incurring significant
costs on a development in the current economic climate.
John
John Allison BSc(Hons)
CSci CChem MRSC SiLC
Principal Land Quality Consultant
Dominion House
Temple Court
Birchwood
Warrington
WA3 6GD
tel. +44 (0) 1925
845156
fax.+44 (0) 1925 845001
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I’d agree with the other
comments below regarding uncertainties in using TEFs. I also agree that
the FSA has rejected their use for the assessment of PAH risk in foods,
as it stands (I also thought a re-assessment of this position was due from
the FSA, but I am not aware if this was released). However it is
probably worth considering the following in the context of contaminated
land assessment:
The use of TEFs and additivity
assumptions for chlorinated dioxins and furans is widely considered to
be acceptable, and is largely based on a peer reviewed scientific consensus
on their use. The same uncertainties related to synergistic effects etc.
apply to dioxins. For PAHs, the data is less rigorous, and there is less
consensus on the use of TEFs. For threshold PAHs, we can use US EPA RfD,
for example. However, for most PAHs (non-threshold) unless a TEF or other
relative potency approach is used, the PAHs are simply not assessed. Application
of TEFs, while uncertain, is more conservative and health protective than
not assessing the other PAHs at all. The FSA approach is to use BaP as
an indicator of risk. To assume that other PAHs are equipotent to BaP would
be overly conservative, and lead to impracticable remediation requirements.
I’d also note that, while the uncertainties associated with TEFs are valid
points, they have been applied by credible international organizations
such as WHO and USEPA.
An alternative to the TEF
method is the Whole Mixture Model approach. The model assumes that the
potency of the PAH mixture is proportional to the B[a]P) content of the
mixture. B[a]P serves as a surrogate for all other PAHs and B[a]Psurrogate
assumes the potency of the entire PAH mixture. The Ontario Ministry of
Environment assign B[a]P surrogate a potency 16 times greater than
the potency of B[a]P on the assumption that this represents the potency
of the entire PAH mixture. The risks assigned to the PAH mixture are then
given by the product of the B[a]P content and the toxic potency of B[a]Psurrogate.
I believe the FSA also recommend a BaP surrogate approach, except that
they suggest that the BaP surrogate potency should be 10 rather than 16.
In any event, if this method is applied, an SSAC for total PAHs (other
than threshold PAHs) would need to be derived, based on the suitable BaP
surrogate potency.
Also, we should note that
the uncertainties related to synergistic affects etc. are not unique to
PAHs – this could apply to other combinations of chemicals as well. However,
even additivity of toxic effects, let alone potentiation of these effects
are typically not assessed as practiced in the UK. At least the TEF approach
addresses the issue of additivity, albeit adjusted for somewhat uncertain
relative potency estimates.
In any event, it should be
noted that the TEF, or other relative potency approach, is more conservative
than the default which is currently applied i.e. other than BaP and threshold
PAHs, the PAH levels are simply not assessed.
I’d appreciate any thoughts.
Aamer Raza
Associate Director
Harrison Group Environmental
Kimberley Street,
Norwich, Norfolk, NR2 2RJ
Phone: 01603-613-111
Email [log in to unmask]
From: Contaminated Land Management
Discussion List [mailto:[log in to unmask]] On
Behalf Of Jonathan Parr
Sent: 13 January 2009 15:40
To: [log in to unmask]
Subject: Re: Toxcic Equivalency Factors
TEFs also doesn't model the synergistic effects
PAHs have on one another either.
Jon
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]]On
Behalf Of John Allison
Sent: 13 January 2009 15:31
To: [log in to unmask]
Subject: Re: Toxcic Equivalency Factors
Simon
It's also worth remembering it's not only the toxicology which may be different
but also the fate and transport of the individual chemicals may be significantly
different, for example contrast the physical properties of naphthalene
with one of the heavier PAH. the approach may overestimate or underestimate
the risks posed by individual PAH depending on the parameters selected
as representative of all PAH.
John Allison BSc(Hons) CSci CChem MRSC SiLC
Principal Land Quality Consultant
Dominion House
Temple Court
Birchwood
Warrington
WA3 6GD
tel. +44 (0) 1925
845156
fax.+44 (0) 1925
845001
email [log in to unmask](Please do not print this
email unless necessary)
TEF are briefly mentioned in the latest SR2 publication from the EA (see
pg 41). As you point out. TEF are used for groups of compounds such
as PAHs, dioxins etc. Significant caution should be applied in using TEFs
as there each PAH may have a different toxicological mode of action and
there is not likely to be sufficient toxicological data available to assess
each compound. As a consequence, the approach could under estimate
the actual risks posed.
In a recent review of the use of TEF for the intake of PAHs in food the
European Food Standard Agency rejected the use of TEF.
Let me know if you want the document.
Ben Rees MSc CGeol
Environmental Geoscientist
Geotechnology Limited
Ty Coed
5 Cefn-yr-Allt
Aberdulais
Neath
SA10 8HE
Direct Line: 07970 890 195
Main Office: 01639 775 293
Fax: 01639 779173
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From: Contaminated Land Management Discussion List [mailto:[log in to unmask]]
On Behalf Of Simon Downs
Sent: 13 January 2009 14:30
To: [log in to unmask]
Subject: Toxcic Equivalency Factors
Hello All
I would like to ask other CLO's what their position is regarding accepting
the use of toxic equivalency factors used in site investigation reports
to obtain screening values for other compounds?
I have a report which has claculated a BaP equivalence for each individual
PAH. This BaP equivalence is then used in the equation below to obtain
a total PAH screening value:
Total PAH Screening Value = BaP CLEA SGV x (Total PAH/Total BaP Equivalency)
I'm not familiar with this method and have not seen it listed in any best
guidance document before?
Any comments greatly appreciated.
Simon Downs
Contaminated Land Officer
East Hampshire District Council
Penns Place Petersfield GU31 4EX
Direct Tel: 01730 234332
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-----Contaminated Land Management Discussion List <[log in to unmask]>
wrote: -----
To: [log in to unmask]
From: Clive Williams <[log in to unmask]>
Sent by: Contaminated Land Management Discussion List <[log in to unmask]>
Date: 16/12/2008 8:49
Subject: Re: SSAC or ......?
Using the reduction in risk level goes contrary to the latest thoughts
of
the HPA on BaP
http://www.hpa.org.uk/web/HPAwebFile/HPAweb_C/1221722398151
The HPA does not support the application of quantitative risk
assessment to derive a specific ELCR for B[a]P for the following reasons
1 The considerable uncertainty in predicting the risk related to a given
dose, particularly when the dose is small
2 The concerns of COC regarding derivation of ELCR from animal data,
3 The lack of societal agreement on what constitutes an acceptable risk
of cancer
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