NIOSH Comments to EPA on the Environmental Protection Agency Request for Comments on the Draft Report: A Cross-Species Scaling Factor for Carcinogen Risk Assessment Based on Equivalence of mg/kg 3/4/Day by R. W. Niemeier, August 4, 1992

摘要

This testimony summarized information and comments from NIOSH regarding the proposal for a unified animal to human scaling factor for carcinogen risk assessment. A scaling factor of body weight raised to the 3/4 power had been proposed. This factor would be adopted by the Environmental Protection Agency, the Food and Drug Administration, and the Consumer Product Safety Commission. The assumptions under which the scaling factor was established were discussed. The graphs contained in the draft reports to illustrate the cross species scaling relationships should be labeled as theoretically expected relationships. Although the draft report made it very clear that case specific information is considered preferable to the use of the default scaling factor and that the development of case specific information is encouraged, the question of just how the case specific information should be used when it is available was left open. The question of pharmacodynamic differences between species in susceptibility to carcinogens was considered.