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Fields and Forests in Flames: Lead and Mercury Emissions from Wildfire Pyrogenic Activity

Environmental Health Perspectives
Environmental Health Perspectives
Publication Date
DOI: 10.1289/ehp.1104672
  • Correspondence
  • Design
  • Mathematics


Correspondence A 56 volume 120 | number 2 | February 2012 • Environmental Health Perspectives upper percentiles in an exposure distribution (Chatterjee et al. 2008). The 90th percentile NHANES dietary values used by the FDA (2010) therefore cannot be characterized as biased toward safety. The National Toxicology Program (2005) and the California Environmental Protection Agency Office of Environmental Health Hazard Assessment (2005) have determined that there is sufficient evidence to consider naphthalene a carcinogen. The FDA’s reliance on an outdated determination by the U.S. EPA (1998) does not constitute a conservative assessment of the health risks associated with exposures to naphthalene. Dickey offers the example of the cancer potency factor for benzo(a)pyrene (BaP) as specifically demonstrating a “bias toward safety” based on his assertion that it reflects the “95% upper confidence limit of the dose–response curve.” This characterization does not match the description of the cancer potency factor on the Integrated Risk Information System (IRIS) website (U.S. EPA 1994). In fact, the cancer potency factor was based on the “geometric mean of four slope factors obtained by differing modeling procedures” (U.S. EPA 1994). Dickey further asserts that the cancer potency factor “could be as low as zero,” which implies no cancer risk and therefore contradicts the designation of BaP as a carcinogen by multiple authorita tive bodies including the FDA (2010), U.S. EPA (1994), Food and Agriculture Organization of the United Nations (FAO)/WHO (2006), and the International Agency for Research on Cancer (IARC 1998). Last, Dickey cites estimates of annual BaP dietary intake, which he attributes to natural occurrence, as a rationale for not considering the lower acceptable exposure levels we proposed in our commentary (Rotkin- Ellman et al. 2012). Unfortunately this logic is severely flawed and does not comport with the FDA’s charge to protect public h

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