B3) Is the rationale for not using increased kidney weight justified and objectively
and transparently presented? Is this rationale correct?
Comment: Three of the reviewers stated that the rationale for not using kidney weight was
correct. Two of these reviewers noted that altered organ weight is a nonspecific effect that is
difficult to interpret. One reviewer stated that he was not qualified to judge the relevance of the
animal data. Another reviewer thought the kidney weight data should be examined further to
ascertain whether it would add to the weight of evidence for defining nephropathy as the critical
effect. Three reviewers indicated that information related to kidney weight could be more
clearly presented.
Response: A NOAEL for increased kidney weight in rats was used as co-critical effect for
deriving the previous RfD for barium (see Section 5.1.4). However, the effect of barium on
kidney weights was variable and not observed in the treatment groups with the greatest
incidences of chemical-related renal lesions (see Table 5–1). Increased kidney weight was
predominantly observed in the subchronic studies. In addition, female rats were the only
chronically exposed animals with significantly increased kidney weights. There are no known
studies that definitively link changes in kidney weight to overt renal toxicity. Nevertheless,
changes in kidney weight have often been utilized as a precursor effect to kidney toxicity in the
absence of information indicating otherwise. In the case of barium, NTP (1994) concluded that
the effects on kidney weight were most likely associated with the treatment-related depression in
weight gain rather than renal toxicity (Dietz et al., 1992). Additional text has been added to
Section 5.1.2 of this Toxicological Review to clarify the rationale for not choosing kidney weight
changes as the critical effect following barium exposure.
C1) Is there a suitable chemical-related dose-response relationship to allow for
benchmark dose modeling of nephropathy? Is discussion of this effect objectively and
transparently presented?
Comment: Four of the reviewers generally agreed with the proposed application of benchmark
dose (BMD) modeling. One reviewer stated that it was inappropriate to use BMD modeling
because the available data do not provide sufficient dose-response information and suggested
that EPA use the NOAEL/LOAEL approach to derive the RfD. One of the four reviewers who
supported the use of BMD modeling indicated that, because of limitations in the barium data
base, he had concerns about the method for choosing a benchmark dose. This reviewer stated
that it would be helpful to provide more information about BMD modeling, particularly the
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limitations associated with it. Another reviewer noted that, while the frequency of nephropathy
was a scientifically valid response to use for modeling, the degree of nephropathy is a subjective
measure recorded by pathologists. This reviewer thought that it would be helpful if more
information was provided about the various types of endpoints EPA uses in their health
assessments and their relative value. Two of the reviewers indicated that the presentation of the
BMD modeling was reasonable and justified.
Response: The draft
Benchmark Dose Technical Support Document (p. 17; U.S. EPA, 2000c),
discusses the minimum data set for calculating a BMD and states “there must be at least a
statistically or biologically significant [underline added for emphasis] dose-related trend in the
selected endpoint.” The trend of increasing incidences of nephropathy was not found to be
statistically significant in mice with chronic exposure to barium in drinking water. Statistical
significance was noted only at the highest dose. However, the trend is considered to be
biologically significant because of the increased severity of the lesions (see Section 5.1.2 of the
Toxicological Review). Additional text discussing the application of BMD modeling for this
endpoint was added to Section 5.1.2 and Appendix B of the Toxicological Review. Additional
information about BMD can be found in the Benchmark Dose Technical Guidance Document
(U.S. EPA, 2000c). Additional information about the types of endpoints that EPA uses in its
health assessments can be found in the guidance documents on the IRIS web site
(http://www.epa.gov/iris/backgr-d.htm).
for increased nephropathy transparently presented? Is the choice of 5% extra risk
scientifically justifiable?
Comment: The reviewers provided divergent responses to this charge question. One reviewer
strongly supported the choice of 5% extra risk for the benchmark response (BMR), rather than
the default 10% value normally used by EPA but thought that a better explanation for this choice
was needed. This reviewer indicated that the scientific rationale for using a lower added risk as
the point of departure could include two points. First, that the histopathological lesions detected
were severe lesions in terms of the magnitude of injury and that these were not subtle effects
observed early in the dose-response relationship pathway. Secondly, post-repair tubular function
is likely to be subpar (i.e., any reversibility is likely to be partial). The reviewer stated that these
irreversible effects are likely to be more grave than reversible effects. This reviewer also added
that kidney disease from all etiologies is more common in older individuals, further indicating
that one should minimize the risk of high intake of a nephrotoxic substance.
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