Pesticide Risk Assessment-- Dietary Exposure

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Pesticide Risk Assessment-- Dietary Exposure Allan Felsot Department of Entomology, WSU-TC Food & Environmental Quality Lab afelsot@tricity.wsu.edu Lecture for 11/17/03

Mandates of the FQPA All tolerances are safe Reasonable certainty of no harm from single or lifetime exposure to residues from all sources of exposure (aggregate risk) Consider multiple residues if same mode of toxic action Consider special sensitivity of children Consider effects on endocrine system Consider carcinogenic potential

Mandate of FIFRA No registration without tolerance Tolerance may be waived, but same degree of risk assessment scrutiny How is tolerance developed? Pre-FQPA Tolerances only consider food sources of exposure Post-FQPA Tolerances consider aggregate exposure Must consider children s health Must consider cumulative exposure

Tolerance Legal limit of residues on food Mechanism of satisfying the mandates of the Federal Food Drug and Cosmetic Act (FFDCA), which is risk oriented, and Federal Insecticide, Fungicide, and Rodenticide Act, which is benefits oriented NOT a safety standard Expression of pesticide residues on food ppm mg/kg µg/g

FQPA Mandate FQPA amendments made pesticide law risk oriented; i.e., tolerances must be safe; No consideration of benefits of pesticide use with several exceptions; Applies to consumers only; Benefits can be considered for ecological risk and worker risk If compound is non-threshold, i.e., EPA deems it is carcinogenic, benefits may be considered if pesticide found necessary to ensure safe food supply and alternatives not available

How Tolerance is Developed Manufacturer proposes tolerance Based on field studies of residues on commodity in major growing regions parts of the country Tolerance always a little higher than the highest residues to hedge bets against exceeding it EPA validates tolerance Risk assessment TMRC (Total Maximum Residue Contribution) analysis

Risk Assessment Hazard Identification Dose-Response Characterization Exposure Assessment Risk Characterization

TMRC Tolerances are residues Toxicological endpoints are doses relative to an effect and body weight The sum of all exposures to residues at the tolerance level cannot exceed the Reference Dose, the safe level by policy design Pre-FQPA: considered food residues only Post-FQPA: tolerance would have to account for aggregate exposures

The Risk Cup Metaphor Old Risk Cup Food FQPA Risk Cup Home & Lawn Water Food FQPA Risk Cup w/ Child Endocrine, Cancer Hazard Home & Lawn Water Food

Field Residue Studies Recommended application rates and one or two levels higher Harvest at the recommended or desired Pre-Harvest Interval (PHI) Normally samples are composited But for many fresh fruits, a single unit (single serving) contributes to acute exposure

TMRC--Basic Procedure Applicable to new registrations Screening tool when tolerances are used as the exposure residue Can use field residues (higher tier or refined analysis) Modify residues by % Crop Treated Need food consumption information USDA Continuing Survey of Food Intake by Individuals Multiply residue tolerance by food consumption of that food to give exposure Sum all exposure possibilities Total exposure cannot exceed RfD

Example Tolerance (old) for chlorpyrifos on apples at 1.5 ppm Tolerance for chlorpyrifos on wheat at 0.5 ppm Average male eats 100 g /day wheat and 75 g/day apples Sum (1.5 µg/g x 75 g/day) + (0.5 µg/g x 100 g/day) = 162.5 µg/day (0.1625 µg/day) Daily Exposure = (162.5 µg/day)/70 kg bw = 2.32 µg/kg bw/day = 232 mg/kg

Example (con td) The RfD for chlorpyrifos is 03 mg/kg/day for chronic exposure Thus, just from the two commodities alone, the RfD is exceeded for an adult Note that average consumption based on the FDA Total Diet Study is only 0015 mg/kg/day (for an infant of 10 kg)

Modern Day Dietary Exposure Assessment Chronic Exposure 70 year lifetime of daily exposure Must meet standards of the chronic RfD Use average residues Use average food consumption data Acute Exposure 24-hour time frame of exposure Must meet acute RfD Considers exposures at 99.9th percentile

Dietary Exposure Assessment DEEM (Dietary Exposure Evaluation Model) Contains USDA CFSII database Three-day record of consumption for about 15,000 people Divided by population subgroup Foods are deconvoluted Pizza is tomatoes, wheat, cheese, and other vegetables as appropriate French fries are potatoes, spices, and vegetable soils

Dietary Exposure Assessment Residues Tolerances (TMRC) Maximum residues in field trials Field residues at 95th percentile Average residues from field Government surveillance and dietary monitoring programs FDA USDA PDP Industry generated market basket surveys

Real Residue Data Advantages Residue Concentration (mg/kg = ppm) Chlorpyrifos Residues in Food Farm Gate Residues Modeled Measured Farm Gate Residues--% of Crop Treated Single Serving Residues-Modeled Market Basket Survey--Avg. Point of Purchase Residues Wright 99 (DowAgro) Cumulative Frequency of Occurrence, Percent

Acute Dietary Exposure Probabilistic assessment employing Monte Carlo analysis The entire distribution of food consumption and food residue data are used Essentially, the two distributions are multiplied together to yield a distribution of exposures Chronic exposure assessment is deterministic Point estimates of food consumption and residues are used

Person 1 Day 1 Person 1 Day 2 Person 1 Day 3 Person 2 Day 1 Food Consumption Matrix (kg/day) 0.20 0.10 0.03 0.06 Milk 0.06 French Fries 0.08 0.04 0.08 0.08 Hot Dog 0.06 Granola Bar 0.02 0.02 0.03 004 003 Cookies 004 006 0.05 0.06 0.20 Pizza 0.04 0.10 Corn flakes 0.75 Raisins 0.05 0.01 0.03 0.02 0.10 Peach 0.10 Apple 0.05 0.10 0.15 Food matrix

Residue Data Matrix (mg/kg) Milk French Fries Hot Dog Granola Bar 0.02 0.02 0.02 Cookies 0.01 0.05 0.06 Pizza 0.20 Corn flakes 0.02 0.04 Raisins 0.03 0.01 0.01 0.02 Peach 0.05 0.02 Apple Sample 1 Sample 2 Sample 3 Sample 4 Food matrix

X X = 16 possible exposures X = 16 possible exposures

Monte Carlo Technique The Monte Carlo program randomly selects a food consumption value for each type of food and matches it to a randomly selected residue value for that food The food consumption and residue value are multiplied together to yield the exposure For every food consumption and residue selection, the process is repeated hundreds or thousands of time to obtain a stable distribution of exposures

Probabilistic Exposure Assessment All exposures are summed together to obtain an overall dietary exposure All the exposures are ranked by percentile to find the 99.9th percentile of exposure The exposure level greater than 99.9% of all other exposures Or, the exposure level only exceeded by 0.1% of the population

Fraction of Population Strawberry Consumption (1-6 year olds) grams per kilogram bw per day DAS 1999

Fraction of All Samples Chlorpyrifos Residues on Strawberries micrograms/gram (µg/g or ppm) DAS 1999

Estimated Exposure to Chlorpyrifos in Strawberries Using a Monte Carlo Analysis (1-6 year old) 0.36 micrograms per kilogram bw per day DAS 1999

Upward Bias of at the 99.9th Percentile Wolt 99

A Tale of Two Risk Assessments Azinphos-methyl CH 3 O S Methyl parathion CH 3 O P S NO 2

Toxicity Parameter mg/kg/day Azinphosmethyl Methyl Parathion Acute Oral LD50 Acute Dermal LD50 Acute NOEL 4.5 2000 Rabbit 200 Rat 0.3 4.5 6 0.11 Chronic NOEL 0.149 0.02

Exposure Endpoints Azinphosmethyl mg/kg/day Methyl Parathion Acute Reference Dose Acute Population Adjusted Dose 3 3 11 011 Chronic Reference Dose Chronic Population Adjusted Dose 149 149 02 002

Methyl Parathion--Acute Dietary Risk Characterization 99.9th Percentile Exposure Pre-Mitigation Post-Mitigation Population Group Exposure mg/kg/day % apad Exposure mg/kg/day % apad U.S. Population 0416 378 0068 60 All infants < 1 yr 0415 377 0067 61 Children 1-6 yrs 0969 881 0086 78 Children 7-12 yrs 0428 388 0087 78

Azinphos-Methyl--Acute Dietary Risk Characterization 99.9th Percentile Exposure Tolerance Residues Real Residues Population Group Exposure mg/kg/day % arfd Exposure mg/kg/day % arfd U.S. Population 5519 85 1781 59 All infants < 1 yr 9934 331 3003 100 Children 1-6 yrs 0.010343 202 3913 130 Children 7-12 yrs 6556 129 2704 90

Hypothetical Dose-Response Curve for Methyl Parathion 100 90 80 70 60 50 40 30 20 10 0 Average Daily Exposure LD 50 Chronic Exposure cpad cnoel 00001 0001 001 01 1 0.01 0.1 1 10 Exposure (mg/kg/day) 100

Hypothetical Dose-Response Curve for Methyl Parathion 100 90 80 70 60 50 40 30 20 10 0 00001 0001 001 Child, 1-6 years Acute Daily Exposure 99.9th Percentile Average Daily Exposure LD 50 apad 01 1 anoel 0.01 0.1 1 Exposure (mg/kg/day) 10 100

Probabilistic Aggregate Exposure Assessment Termiticide Use Crack & Crevice Treatment Lawn Treatment Dietary Frequency + + + Exposure per day Frequency Total Exposure for All Uses per day