As noted in Chapter 4, the health effects of exposure to formaldehyde evaluated by the Environmental Protection Agency (EPA) can be characterized as portal-of-entry effects or systemic effects. In this chapter, the committee reviews EPA’s evaluation of systemic health effects, including immunotoxicity, neurotoxicity, reproductive and developmental toxicity, and lymphohematopoietic cancers. The committee determined whether EPA identified the appropriate studies, whether the studies were thoroughly evaluated, whether hazard identification was conducted appropriately in light of EPA guidelines, and whether the best studies were advanced for calculation of the reference concentration (RfC) or unit risk.
Chapter 3 of the present report addresses the question of systemic bioavailability of inhaled formaldehyde. High reactivity and extensive nasal absorption of formaldehyde restrict systemic delivery of inhaled formaldehyde beyond the upper respiratory tract and major conducting airways of the lung. Indeed, the weight of evidence suggests that it is unlikely for formaldehyde to appear in the blood as an intact molecule, except perhaps when exposure doses are high enough to overwhelm the metabolic capability of the tissue at the site of exposure. Thus, systemic responses are unlikely to arise from the direct delivery of formaldehyde (or its hydrated form methanediol) to a distant site in the body. However, it is important to distinguish between systemic delivery of formaldehyde and systemic effects. The possibility remains that systemic delivery of formaldehyde is not a prerequisite for some of the reported systemic effects seen after formaldehyde exposure. Those effects may result from indirect modes of action associated with local effects, such as irritation, inflammation, and stress. Therefore, the committee reviewed EPA’s evaluation of the systemic effects and determined whether the evidence presented supported EPA’s conclusions.
Below are the first 10 and last 10 pages of uncorrected machine-read text (when available) of this chapter, followed by the top 30 algorithmically extracted key phrases from the chapter as a whole.
Intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text on the opening pages of each chapter.
Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.
Do not use for reproduction, copying, pasting, or reading; exclusively for search engines.
OCR for page 92
5
Systemic Health Effects
As noted in Chapter 4, the health effects of exposure to formaldehyde
evaluated by the Environmental Protection Agency (EPA) can be character-
ized as portal-of-entry effects or systemic effects. In this chapter, the commit-
tee reviews EPA’s evaluation of systemic health effects, including immu-
notoxicity, neurotoxicity, reproductive and developmental toxicity, and
lymphohematopoietic cancers. The committee determined whether EPA iden-
tified the appropriate studies, whether the studies were thoroughly evaluated,
whether hazard identification was conducted appropriately in light of EPA
guidelines, and whether the best studies were advanced for calculation of the
reference concentration (RfC) or unit risk.
Chapter 3 of the present report addresses the question of systemic
bioavailability of inhaled formaldehyde. High reactivity and extensive nasal
absorption of formaldehyde restrict systemic delivery of inhaled formaldehyde
beyond the upper respiratory tract and major conducting airways of the lung.
Indeed, the weight of evidence suggests that it is unlikely for formaldehyde to
appear in the blood as an intact molecule, except perhaps when exposure doses
are high enough to overwhelm the metabolic capability of the tissue at the site
of exposure. Thus, systemic responses are unlikely to arise from the direct
delivery of formaldehyde (or its hydrated form methanediol) to a distant site in
the body. However, it is important to distinguish between systemic delivery of
formaldehyde and systemic effects. The possibility remains that systemic de-
livery of formaldehyde is not a prerequisite for some of the reported systemic
effects seen after formaldehyde exposure. Those effects may result from indi-
rect modes of action associated with local effects, such as irritation, inflamma-
tion, and stress. Therefore, the committee reviewed EPA’s evaluation of the
systemic effects and determined whether the evidence presented supported
EPA’s conclusions.
92
OCR for page 92
Systemic Health Effects 93
IMMUNOTOXICITY
Immunomodulation or immunotoxicity occurs when environmental factors
(such as stress, health status, and chemical exposure) change the homeostatic
processes that regulate the immune system in susceptible populations. The con-
sequences of immunotoxicity can be highly divergent and depend on the envi-
ronmental factor, the duration and timing of the exposure, the overall health
status of the exposed person, and the route of exposure. Immunotoxicity may
occur from direct effects on immune cells or from indirect effects on various cell
components, such as altered endocrine function. It may also occur at an anat-
omic site that is distant from the point of entry. Indeed, the systemic nature of
the immune system may mean that an exposure at one site causes damaged or
modified cells to move to another location in the body where they may mediate
the effects of the toxicant.
Adverse health effects associated with immunotoxicity may include higher
infection rate; alterations in lymphocyte cell populations; hyperactivity of im-
mune cells, such as increased respiratory activity (increased production of reac-
tive oxygen and reactive nitrogen species) and cytokine production; autoimmu-
nity; altered immune-cell trafficking throughout the body; increased allergy or
atopy; and susceptibility to cancer. Research to determine the immunotoxicity of
an agent focuses on those and other responses. EPA has developed a health-
effects test guideline for immunotoxicity (EPA 1998a).
In the case of formaldehyde, as has been discussed elsewhere in the pre-
sent report, most of or all the direct effects occur at the point of entry in the up-
per respiratory tract. Immune cells in the bronchial and nasal associated lym-
phoid tissue (BALT and NALT) are most likely proximal targets of
formaldehyde. Understanding the potential immunotoxicity of formaldehyde is
therefore of critical importance.
Adverse effects of formaldehyde on BALT and NALT may be manifested
systemically because these lymphoid cells migrate to the lymph nodes, spleen,
liver, peripheral blood, and other immune tissues. Specifically, most BALT and
NALT cells belong to the arm of the immune system referred to as the innate
immune system. The role of the innate immune cells is to recognize and respond
to tissue damage, apoptotic cells, and evolutionarily conserved protein and gly-
coprotein patterns expressed on bacteria, viruses, parasites, and other pathogens.
The consequences of innate immune-cell recognition of pathogen-associated
molecular patterns (PAMPs) are to increase production of reactive oxygen spe-
cies, to engulf the particles expressing PAMPs, and to migrate systemically
where the potential infectious agent is presented to the adaptive arm of the im-
mune system. The role of the adaptive arm of the immune system is to produce
cytokines, which activate antibody production, increase inflammation, and re-
cruit lymphocytes to the site of infection.
OCR for page 92
94 Review of EPA’s Draft IRIS Assessment of Formaldehyde
Consequently, the systemic nature of the immune system and interplay be-
tween the innate and adaptive arms of the immune system suggest a plausible
potential target of formaldehyde despite its limited distribution beyond the point
of entry. Moreover, potential alterations of the innate immune cells mediated by
formaldehyde may have profound effects on the adaptive and peripheral immune
system. The draft IRIS assessment summarizes a number of human and animal
studies that describe formaldehyde-induced immunotoxicity. Although many of
the appropriate studies were identified, a more careful evaluation of the relative
strengths and weaknesses of the key studies should have been provided. More-
over, additional weight could have been given to animal studies in which expo-
sure assessment was more rigorously controlled and a diverse set of end points
was examined. The committee recognizes that differences exist in leukemia sen-
sitivities between animals and humans. However, the differences in responses
may not be relevant for other immunotoxicities, such as respiratory burst activ-
ity, sensitivity, and atopy.
Study Identification
The draft IRIS assessment discusses immunologic end points affected by
formaldehyde exposure on the basis of human and animal studies in the com-
piled database of published studies. The committee did not perform an addi-
tional literature search, but it appears that, in general, the appropriate studies
were identified and adequately discussed. Specifically, the draft IRIS assessment
presents studies designed to address the following questions:
Does formaldehyde exposure increase upper respiratory tract infec-
tions?
Does formaldehyde induce lymphocyte associated respiratory burst ac-
tivity and inflammation?
Is formaldehyde exposure associated with allergic sensitivity or atopy?
What is the toxicologic significance of antibody responses directed
against formaldehyde or formaldehyde-protein complexes?
The structure of the draft assessment is such that the research questions
regarding human and animal end points are addressed separately. As will be
discussed below, the committee finds that a more integrated approach in which
the human and animal studies of a given immunologic end point are discussed
and evaluated together would result in a more concise and transparent report.
Study Evaluation
In addressing the questions above, the draft IRIS assessment presents nu-
merous studies that provide data that suggest that formaldehyde is immuno-
OCR for page 92
Systemic Health Effects 95
modulatory (EPA 2010). Specifically, in addressing the question of what effect
formaldehyde has on susceptibility to upper respiratory tract infections, the draft
cites Holness and Nethercott (1989), Krzyzanowski et al. (1990), and Lyapina et
al. (2004). The Holness and Nethercott (1989) and Lyapina et al. (2004) studies
were conducted in occupational settings, and the Kyzyzanowski et al. (1990)
study was conducted in homes in which formaldehyde concentrations were
measured. The concentrations in the occupational settings were 0.71-1.55 ppm,
and the average concentration in the home study was 26 ppb. As reported in the
draft assessment, all three studies showed an association between formaldehyde
exposure and increased incidence of upper respiratory tract infections. No di-
rectly comparable animal studies that would have strengthened or weakened
those findings are cited. However, formaldehyde exposure at higher exposure
concentrations (2 ppm or higher) has been shown to reduce mucociliary appara-
tus function in the rodent (Morgan et al. 1986). Similar effects, such as slowed
mucociliary clearance, have been seen in occupationally exposed people (Holm-
ström and Wilhelmsson 1988). The mucociliary apparatus is an important bar-
rier to infection and other exogenous agents, so the finding is supportive of the
human studies. The three key studies used by EPA reflect the state of the science
with respect to formaldehyde and virally induced upper respiratory tract infec-
tions. Given the small number of studies, this section of the draft IRIS assess-
ment would have been greatly improved by a critical evaluation of those studies.
Regarding the question of whether formaldehyde affects lymphocyte res-
piratory burst activity or inflammation, several studies in humans and animals
are listed. Specifically, Lyapina et al. (2004) used flow cytometry to measure
changes in neutrophil respiratory burst activity in occupationally exposed work-
ers who had chronic bronchitis. A weakness of the study is that the assay used to
measure respiratory burst activity is not specific. Moreover, the details of the
study preclude concluding whether formaldehyde exposure or a chronic bron-
chial condition in the selected subjects was the cause of the changed cellular
activity. However, Dean et al. (1984) and Adams et al. (1987) performed animal
studies using 3-week exposures to formaldehyde at 15 ppm and measured
changes in peritoneal macrophage hydrogen peroxide production. As shown in
Table 4-47 of the draft IRIS assessment, peroxide production was increased in
response to macrophage activation. If the results of the studies were synthesized,
EPA could strengthen its conclusion that formaldehyde exposure affects respira-
tory burst activity in the immune system. Moreover, the animal studies demon-
strate effects on the innate immune system at a distant site (for example, the
peritoneum); this lends credence to the biologic plausibility of systemic effects
caused by formaldehyde exposure.
Studies covering sensitivity and atopy are similarly listed and described in
the draft IRIS assessment with little evaluation of the strengths and weaknesses
of the cited work. Moreover, in the section describing human studies, a substan-
tial amount of text is devoted to assessing whether exposed people generate IgE
antibodies against formaldehyde. IgE antibodies are generated against allergic
agents and chemical haptens (chemicals complexed with endogenous proteins
OCR for page 92
96 Review of EPA’s Draft IRIS Assessment of Formaldehyde
that elicit an immune response). Although discussion of IgE antibodies against
formaldehyde is not a trivial question, this section in the draft assessment could
be condensed. Furthermore, an additional question to ask in the section “Sensi-
tivity and Atopy” would be, Does exposure to formaldehyde modulate responses
to known allergens, such as dust mites, ragweed, animal dander, and mold
spores? If there has been research on that subject, it is not presented in the draft
assessment with respect to human exposures.
In comparison, the results of many studies in animal models support a
conclusion that formaldehyde exposure modifies allergic responses. Specifi-
cally, Tarkowski and Gorski (1995), Riedel et al. (1996), and Lino dos Santos
Franco et al. (2009) found increased sensitivity in rodents that were coexposed
to a model allergen (ovalbumin) and formaldehyde. Sadakane et al. (2002) and
Ohtsuka et al. (2003) found changes in inflammatory cytokine production in the
lungs after formaldehyde exposure. Several other studies summarized in Table
4-54 of the draft IRIS assessment showed more modest results or no effect of
formaldehyde. The disparate observations may be due partly to the use of differ-
ent rodent species and strains in the studies. Moreover, the exposure protocols
varied widely. In some cases, animals were pre-exposed to formaldehyde and
then sensitized; in other studies, sensitization occurred before formaldehyde
exposure; and in others, sensitization and exposure occurred simultaneously.
Although the committee agrees that each type of protocol appropriately repli-
cates a real-world exposure scenario, the section deserves a robust rubric to
evaluate the strengths and weaknesses of the studies presented. That is particu-
larly important given that the section “Sensitization and Atopy” of the draft IRIS
assessment concludes with a statement that “taken as a whole, the results sup-
port the finding that formaldehyde exposure can aggravate a type I hypersensi-
tivity response” (EPA 2010, p. 4-335). On the basis of the review currently pro-
vided, the committee cannot agree with that conclusion because no clear
framework for drawing it is presented.
Hazard Identification and Use of EPA Guidelines
Hazard identification for immunotoxicity was conducted and reported in a
generally appropriate fashion, given EPA guidelines. However, the language
used in the review of some studies could be improved. For example, the discus-
sion of Riedel et al. (1996), which documented airway sensitivity in guinea pigs
in response to formaldehyde at 0.13 or 0.25 ppm, uses the term biologically sig-
nificant (EPA 2010, p. 4-319). The term is used in the absence of a statement of
a statistically significant effect by the study authors. Thus, EPA should provide a
justification for its conclusion that the effect was biologically significant and
indicate whether additional statistical analyses were performed.
In addition, the immune-hazard identification section could have been
clearer with a discussion summarizing immune effects of formaldehyde. Spe-
cifically, consistencies between human and animal findings regarding inflamma-
OCR for page 92
Systemic Health Effects 97
tion, target-cell types, and airway responses should be noted. Cells of the innate
immune system appear to be targets or mediators of formaldehyde-induced im-
munotoxicity in animal and human studies, and a concluding statement contain-
ing that information would be useful.
Study Selection for Calculation of Reference Concentration and
Identification of Point of Departure
The sections on immunotoxicity do not identify any studies for deriving a
candidate RfC. Thus, no candidate RfC was calculated for the immunotoxic ef-
fects of formaldehyde.
Conclusions and Recommendations
The systemic nature of the immune system and the interplay between the
innate and adaptive arms of the immune system provide a plausible potential
target of formaldehyde, despite its limited distribution beyond the point of entry.
The draft IRIS assessment summarizes many human and animal studies that
describe formaldehyde-induced immunotoxicity. The committee agrees with
EPA’s decision not to calculate a candidate RfC for immunotoxicity at this time.
The committee recommends, however, that EPA address the following in
the revision of the formaldehyde draft IRIS assessment:
Provide a more careful evaluation of the relative strengths and weak-
nesses of the key studies.
Consider giving additional weight to animal studies in which exposure
assessment was more rigorously controlled.
NEUROTOXICITY
Neurotoxicity is defined as any adverse effect on the chemistry, structure,
or function of the nervous system during development or in maturity. Neurotox-
icity may be permanent or reversible, and it can be expressed as neuropathologic
effects or as neurochemical, electrophysiologic, or behavioral changes. In gen-
eral, chemical-induced changes in the structure or persistent behavioral, neuro-
chemical, or neurophysiologic changes in the nervous system are regarded as
neurotoxic effects. Reversible effects occurring at doses that could endanger
performance in the workplace or that are associated with a known neurotoxi-
cologic mode of action are also considered adverse. Formaldehyde exposure via
inhalation has been shown to affect nervous-system function adversely in labo-
ratory animals and humans, although there are few data on formaldehyde-
induced neurologic effects in humans.
OCR for page 92
98 Review of EPA’s Draft IRIS Assessment of Formaldehyde
Study Identification
EPA appears to have identified all available relevant literature on formal-
dehyde neurotoxicology; the committee could not identify any important studies
that were not included. The draft IRIS assessment identifies seven neurotoxicity
studies that are considered as candidates for RfC development, most notably the
epidemiologic studies by Weisskopf et al. (2009) and Kilburn et al. (1985,
1987). Several experimental rat studies are also identified as candidate studies
for RfC development. Experimental mouse studies are noted, but they are dis-
missed because of confounding issues. All studies addressed exposures of short
duration, so information regarding the relationship between formaldehyde toxic-
ity and exposure duration is sparse.
Study Evaluation
The evaluation of the epidemiologic studies in the draft IRIS assessment
focused on Weisskopf et al. (2009) and Kilburn et al. (1985, 1987). Weisskopf
et al. (2009) reported a statistically significant association (relative risk, 2.47;
95% CI, 1.58-3.86) between self-reported years of formaldehyde exposure and
death from amyotrophic lateral sclerosis (ALS). The draft assessment concludes
that the study supports the “causal association of neuropathological effects in
humans following long-term formaldehyde exposure” (EPA 2010, p. 4-476).
The committee, however, is not convinced that the study established a causal
association. EPA’s conclusion of causality between formaldehyde inhalation and
the development of ALS is premature, is supported by an isolated study with
limited exposure data, and lacks sufficient evidence of biologic plausibility. In-
deed, the study authors stated that “the increased risk attributed to formaldehyde
could be the result of exposure to some other unmeasured factor commonly as-
sociated with formaldehyde” (Weisskopf et al. 2009). Kilburn et al. (1985) re-
ported that a group of 76 female histology technicians displayed statistically
significantly greater frequencies of lack of concentration and loss of memory,
disturbed sleep, impaired balance, variations in mood, and irritability than did a
control group of 56 unexposed female clerical workers. The technicians had
been employed for 2-37 years (mean, 12.8 years). Analysis of workplace air
samples indicated the presence of several solvents, including formaldehyde (0.2-
1.9 ppm), xylene (3.2-102 ppm), chloroform (2-19.1 ppm), and toluene (8.9-12.6
ppm). Thus, exposure to xylene and other solvents most likely contributed to the
observed neurobehavioral effects. Kilburn (1994) also reported that three
anatomists and one railroad worker, occupationally exposed to airborne formal-
dehyde for 14-30 years, showed impaired performance on choice reaction time,
abnormal balance, digit symbol, and perceptual motor speed.
EPA’s review of the candidate animal studies is largely descriptive and
lacked a systematic or specified format for study evaluation. None of the candi-
date studies adhered to EPA’s neurotoxicity-testing guidelines (EPA 1998b).
OCR for page 92
Systemic Health Effects 99
Several studies used designs that deviated substantially from the testing guide-
lines and common practice. In particular, animal studies performed by Malek
and co-workers (2003a) used extremely short-duration (3-min) motor-activity
test sessions. EPA neurotoxicity-test guidelines explicitly state that the test ses-
sion should be “of sufficient duration to allow motor activity to approach steady-
state levels during the last 20 percent of the session for control animals” (EPA
1998b, p. 39). There is no indication in the original study that that criterion was
reached; indeed most motor-activity test sessions require at least 20 min to reach
asymptotic levels (Fitzgerald et al. 1988). That deficiency of the study was not
raised by EPA in its review. EPA also largely ignored the absence of exposure-
response relationships for some behavioral end points.
No mode of action has been postulated for formaldehyde-induced neu-
rologic effects. EPA concluded that behavioral changes seen in formaldehyde-
exposed animals are unlikely to be attributable to the irritant properties of for-
maldehyde. The committee does not support that conclusion. For example, Sorg
and Hochstatter (1999) observed alterations in formaldehyde-exposed rats in an
odor-cued test of learning. It is possible that formaldehyde exposure resulted in
olfactory epithelial injury sufficient to affect olfaction. Other studies (for exam-
ple, Sorg et al. 2001) suggest that stress responses, such as altered cortisol con-
centrations, occur in formaldehyde-exposed animals. It is plausible that those
changes occur because of nasal irritation and other local responses. Stress and
related alterations in stress hormones are important potential confounders be-
cause they are associated with deficits in hippocampal-based memory function,
alterations in hippocampal structure, and other neurologic responses (Pavlides et
al. 2002; Conrad 2006; McEwen 2008; Zuena et al. 2008). Another concern
raised by the committee is that the high reactivity of formaldehyde would not
lend itself to substantial delivery to the nervous system.
The draft IRIS assessment indicates that there is some question as to
whether formaldehyde should be considered a direct neurotoxicant (EPA 2010).
Indeed, some portions of the assessment suggest that systemic effects are unex-
pected at formaldehyde concentrations less than 20 ppm. That idea is inconsis-
tently presented in other parts of the document. The inconsistency in the docu-
ment should be resolved.
Hazard Identification and Use of EPA Guidelines
EPA has developed guidelines for neurotoxicity risk assessment (EPA
1998b). One cornerstone of the guidelines is the definition of neurotoxicity as
an adverse change in the structure or function of the central or peripheral
nervous system after exposure to an agent. Changes in motor activity, learning
and memory, and other end points after formaldehyde exposure meet the defi-
nition of an adverse response. Although a mode of action for formaldehyde
neurotoxicity is lacking, that gap does not preclude drawing a conclusion. The
EPA guidelines state that “knowledge of exact mechanisms of action is not,
OCR for page 92
100 Review of EPA’s Draft IRIS Assessment of Formaldehyde
however, necessary to conclude that a chemically induced change is a neuro-
toxic effect” (EPA 1998b, p. 10).
The neurotoxicity guidelines state that “the interpretation of data as in-
dicative of a potential neurotoxic effect involves the evaluation of the validity
of the database…There are four principal questions that should be addressed:
whether the effects result from exposure (content validity); whether the effects
are adverse or toxicologically significant (construct validity); whether there
are correlative measures among behavioral, physiological, neurochemical, and
morphological endpoints (concurrent validity); and whether the effects are
predictive of what will happen under various conditions (predictive validity)”
(EPA 1998b, p. 10). The draft IRIS assessment does not indicate whether
those criteria were considered in the selection of the key studies. Indeed, data
supporting concurrent and predictive validity are largely lacking for formalde-
hyde.
The EPA guidelines also state that “the minimum evidence necessary to
judge that a potential hazard exists would be data demonstrating an adverse
neurotoxic effect in a single appropriate, well-executed study in a single ex-
perimental animal species” (EPA 1998b, p. 53). There is concern that the se-
lected studies are not sufficiently robust in design to be considered “well exe-
cuted” for the purpose of neurotoxicity hazard identification. For example,
motor-activity responses seen by Malek et al. (2003 a,b) in different test ses-
sions in control animals were quite variable. Malek et al. also examined for-
maldehyde effects on learning and memory using a labyrinth swim maze, a
test that could be affected by motor activity. Furthermore, the available human
data have important shortcomings—such as limited exposure assessments and
coexposures to neurotoxic solvents—that preclude a determination that for-
maldehyde is neurotoxic to humans.
Study Selection for Calculation of Reference Concentration and
Identification of Point of Departure
EPA concluded that the available epidemiologic studies did not provide
sufficient exposure information to permit derivation of a point of departure for
use in quantitative dose-response assessment. The draft IRIS assessment states
that “confounding exposures to other neurotoxic solvents and inconsistent re-
sults prevent drawing definitive conclusions concerning the neurotoxicity of
formaldehyde from these studies” (EPA 2010, p. 4-97). The committee agrees
with EPA’s decision not to use the human studies to calculate a candidate RfC.
Several studies in mice demonstrated dose-related neurotoxic effects after
formaldehyde exposure. The studies were not considered for RfC development
because the observed results might have been confounded by formaldehyde-
induced reflex bradypnea and related physiologic responses. The committee
agrees with EPA’s decision not to use the experimental mouse studies for RfC
development for the reasons cited.
OCR for page 92
Systemic Health Effects 101
EPA identified several experimental studies in rats that might be appropri-
ate for candidate RfC development. According to EPA, the selected rat behav-
ioral studies were not confounded by reflex bradypnea inasmuch as the effect
occurs in rats only at doses above those at which the neurologic effects of con-
cern were seen. EPA considered the studies by Malek et al. (2003a,c) that re-
ported effects at low exposures to be the most robust. The draft IRIS assessment
does not provide criteria that define why the studies were considered “robust”
other than that the changes were observed at low concentrations. Malek et al.
(2003c) found statistically significant reductions in motor activity after a single
2-hr exposure at 130-5,180 ppb (with testing 2 hr after cessation of exposure).
Malek et al. (2003a) also showed a statistically significant reduction in perform-
ance on a learning task at similar exposures (100-5,400 ppb) when 2-hr expo-
sures were repeated on 10 consecutive days (p < 0.05); performance was evalu-
ated 2 hr after cessation of exposure, and concentration-related learning deficits
were seen at all concentrations. The study was eventually selected as the key
study by EPA. As noted earlier, no study was conducted according to existing
EPA health-effects test guidelines for the conduct of a neurotoxicity screening
battery or for evaluation of neurotoxicity end points (EPA 1998b). Accordingly,
the studies have several methodologic shortcomings in how behavior was as-
sessed by the investigators. In addition, neither study assessed subchronic or
longer exposures; this draws into question their appropriateness for deriving a
chronic RfC. The committee did not identify an alternative study that would be
preferred for deriving a candidate RfC.
Malek et al. (2003a) reported a lowest observed-adverse-effect level
(LOAEL) of 100 ppb in rats for neurologic and behavioral toxicity (impaired
learning) after repeated exposure (2 hr/day over 10 days). A no-observed-
adverse-effect level (NOAEL) was not identified for that effect. The committee
notes that the point of departure for the study was subject to an exposure ad-
justment (Table 5-1 in the draft IRIS assessment). Testing was conducted 2 hr
after exposure, and the duration was adjusted by EPA to 4 hr to include the en-
tire period between start of exposure and testing. The committee disagrees with
the duration adjustment because of the uncertainty in continuous-exposure ad-
justments for exposure durations as short as that used in the experimental study.
The study was not carried forward for derivation of a candidate RfC, partly be-
cause of the uncertainty in extrapolating from the exposure conditions in the
study to a chronic-exposure scenario; the committee agrees with EPA’s decision
in this regard.
Conclusions and Recommendations
The committee concludes that the draft IRIS assessment overstates the
evidence that formaldehyde is neurotoxic. The selected studies are not suffi-
ciently robust in design to be considered well executed for the purpose of neu-
rotoxicity-hazard identification. One study of rats by Malek et al. (2003a) was
OCR for page 92
102 Review of EPA’s Draft IRIS Assessment of Formaldehyde
advanced by EPA for consideration. It was considered to offer information on
an outcome relevant to humans at an appropriate concentration. Appropriately,
the study was not used to calculate a candidate RfC, partly because of uncer-
tainty in extrapolating from the exposure conditions in the study to a chronic-
exposure scenario.
The committee recommends that EPA address the following in the revi-
sion of the formaldehyde draft IRIS assessment:
Re-evaluate its conclusions that behavioral changes are unlikely to be
related to irritant properties of formaldehyde.
Resolve inconsistencies regarding the concentration at which sys-
temic effects of formaldehyde exposure are expected. The draft IRIS assess-
ment indicates that there is some question as to whether formaldehyde should
be considered a direct neurotoxicant, and some portions of the assessment
suggest that systemic effects are unexpected at formaldehyde concentrations
less than 20 ppm. That statement is inconsistently made in other parts of the
document.
REPRODUCTIVE AND DEVELOPMENTAL TOXICITY
The reproductive and developmental outcomes considered in the draft
IRIS assessment comprise a broad spectrum of specific outcomes, including
infertility, low birthweight, spontaneous abortion, birth defects, functional
deficits, and other altered health conditions. Each outcome may have a distinct
pathogenesis and etiology. A variety of environmental, occupational, lifestyle,
and genetic factors have been hypothesized to be associated with an increased
risk of those outcomes.
Formaldehyde’s potential mode of action for reproductive and develop-
mental outcomes is uncertain; several modes have been suggested by animal
studies, including endocrine disruption, genotoxic effects on gametes, and
oxidative stress or damage. Critical questions remain about the association
between inhalation exposure and the potential for adverse reproductive and
developmental effects. EPA reviewed epidemiologic and animal studies that
evaluated formaldehyde exposure in relation to fecundability (the per-cycle
probability of conception), spontaneous abortion, birth defects, low birth-
weight, and reproductive effects (EPA 2010). EPA concluded that the epide-
miologic studies provided evidence of a convincing relationship between oc-
cupational exposure to formaldehyde and adverse reproductive outcomes in
women. EPA selected a single study (Taskinen et al. 1999) that evaluated the
association between formaldehyde and fecundability, using time to pregnancy
for determination of a candidate RfC.
OCR for page 92
Systemic Health Effects 107
The epidemiologic studies provide only a suggestive pattern of associa-
tion. However, to be consistent with EPA guidelines, an RfC can be calculated
by using the best available study evidence. EPA chose the study by Taskinen et
al. (1999) to derive a candidate RfC. That study of female Finnish wood workers
examined estimated workplace formaldehyde exposure primarily in relation to
time to pregnancy but secondarily to other outcomes, including endometriosis
and spontaneous abortion. The study had multiple strengths, including the na-
tional identification of workers and birth outcomes; industrial-hygienist assess-
ment of potential exposures, including workplace measurements; and adjustment
for multiple potential confounders, including other exposures. The study weak-
nesses included the use of a mailed questionnaire for exposure and covariate
information; potential recall bias as to work tasks; no consideration of work ac-
cidents; inadequate description of exposure sources, such as the number of
measurements taken; and the use of measurements from workplaces other than
their own specific workplace that varied by exposure category. Furthermore,
participant response to the questionnaire was less than outstanding.
EPA chose that study from the available epidemiologic studies of repro-
ductive effects because of its overall strengths, the low likelihood of an impor-
tant effect of selection bias, and consistency with other epidemiologic studies
and animal evidence on fetal loss (EPA 2010). Furthermore, the draft IRIS as-
sessment notes that the study population was well defined and adequately se-
lected to allow examination of health effects in people who had different expo-
sures. The committee agrees that it has a number of important strengths
compared with the other reproductive epidemiologic studies evaluated. Notable
strengths include exposure assessment, a relatively easily measured outcome
(time to pregnancy), and assessment of confounding, such as by occupational
exposures.
The draft IRIS assessment indicates that the study could be used for three
outcomes: miscarriage, endometriosis, and decreased fecundity density ratio
(FDR). However, because of the concerns about the miscarriage and endome-
triosis analyses, the FDR results were chosen as the critical effect for a candidate
RfC. For example, the spontaneous-abortion analysis was not the primary aim,
and the exposure and response pattern was not consistent with the increased risk
found in the low-exposure group. In addition, the spontaneous-abortion analysis
did not adjust for all covariates used in the FDR analysis. EPA also noted that
the endometriosis results may be confounded by other solvents. The committee
agrees that the choice of outcome from Taskinen et al. (1999) is appropriate for
the reasons provided in the draft IRIS assessment.
However, the committee is concerned that basing an RfC on a single hu-
man study in a minimal human database is problematic. EPA guidelines state
that “a reference value based on a single study would likely have a high degree
of uncertainty” (EPA 2002, p. 4-20). Although multiple studies of varied quality
have assessed spontaneous abortions, the study by Taskinen et al. (1999) is the
only one that measured time to pregnancy.
OCR for page 92
108 Review of EPA’s Draft IRIS Assessment of Formaldehyde
Conclusions and Recommendations
The review of the reproductive and developmental outcomes in the draft
IRIS assessment includes relevant outcomes and literature. It does not consis-
tently provide a critical evaluation of the quality of publications and data pre-
sented or note strengths and weaknesses of each study. That is especially the
case with the animal studies. The rationale for the assessment of the body of the
epidemiologic evidence as convincing is not well articulated. Issues regarding
the potential portal of entry and mode of action in relation to reproductive and
developmental outcomes are not integrated into the weight-of-evidence discus-
sion. Nonetheless, despite the shortcomings in the database and aspects of the
review, the most relevant epidemiologic study and specific outcome are ad-
vanced for derivation of a candidate RfC. The point of departure is appropriately
selected.
The committee recommends that EPA address the following in the revi-
sion of the formaldehyde draft IRIS assessment:
Provide a consistent critical evaluation of the study quality and data
presented, particularly strengths and weaknesses of each study. That is espe-
cially needed for the animal studies.
Articulate better the basis of the assessment of the epidemiologic evi-
dence.
Integrate better the issues surrounding systemic delivery and mode of
action for reproductive and developmental outcomes into the weight-of-evidence
discussion.
LYMPHOHEMATOPOIETIC CANCERS
Lymphohematopoietic (LHP) cancers are a heterogeneous group of can-
cers that encompass a wide variety of leukemias and lymphomas. Although they
all arise from the hematopoietic system, these cancers are often derived from
cells of different origin, can demonstrate unique genetic abnormalities, and may
arise in different tissues (Figure 5-1). Those differences indicate that their etio-
logic bases may be distinct.
Although the draft IRIS assessment explores specific diagnoses—such as
acute myeloid leukemia (AML), chronic myeloid leukemia (CML), and Hodg-
kin lymphoma and multiple myeloma (see, for example, EPA 2010, Table 4-
92)—the determinations of causality are made for the heterogeneous groupings
“all LHP cancers,” “all leukemias,” and “myeloid leukemias.” The grouping “all
LHP cancers” includes at least 14 biologically distinct diagnoses in humans
(Figure 5-1) and should not be used in determinations of causality. The draft
IRIS assessment should include information about the relative incidence of the
OCR for page 92
Systemic Health Effects 109
FIGURE 5-1 Origins of lymphohematopoietic cancers. Cells of origin, common ge-
netic abnormalities, and tissues of origin are indicated for diverse hematopoietic ma-
lignancies. Compared with Figure 4-32 in the draft IRIS assessment, this figure clari-
fies the distinct cells of origin of acute myeloblastic leukemia (AML), T-cell acute
lymphoblastic leukemia (T-ALL), B-cell acute lymphoblastic leukemia (B-ALL), and
most mature leukemias and lymphomas. Abbreviations: ALK, anaplastic lymphoma
kinase; BCL2, B-cell leukemia 2; BCR-ABL, breakpoint cluster region-Abelson mur-
ine leukemia; and MYC, myelocytomatosis viral oncogene homolog.
leukemia subtypes because the contribution of AML, CML, “myeloid leuke-
mias,” and “all leukemias” to the grouping “all LHP” may not be obvious to
readers and may help with interpretation (Figure 5-2).
Another important topic of discussion in the draft IRIS assessment is that
of potential modes of action of formaldehyde as a cause of diverse LHP cancers.
As discussed in Chapter 3 of the present report, the available experimental data
indicate that formaldehyde itself does not penetrate beyond the superficial layer
of the portal of entry, the epithelium of the nasopharynx. Therefore, long-used
models of chemical leukemogenesis in which there is direct toxicity to hemato-
poietic cells in the bone marrow are unlikely to explain the proposed distal ef-
fect of formaldehyde on hematopoietic precursors. However, evidence of for-
maldehyde-induced DNA adducts and DNA damage in circulating lymphocytes
suggests that hematopoietic cells might be affected by inhaled formaldehyde,
presumably at the nasal epithelium or nasal-associated lymphoid tissue (NALT).
EPA and others propose a model in which lymphoid precursors or hematopoietic
stem cells circulate or migrate to the nasal epithelium, where they are directly
exposed to formaldehyde and ultimately result in diverse LHP cancers. As the
draft IRIS assessment states, that hypothesis seems plausible for Hodgkin lym-
phoma and multiple myeloma, which arise from precursors in the peripheral
OCR for page 92
110 Review of EPA’s Draft IRIS Assessment of Formaldehyde
Estimated annual new diagnoses
All LHP 140,000
All leukemias 42,000
Myeloid leukemias 18,000
AML 13,000
CML 5,000
Hodgkin lymphoma 10,000
Myeloma 20,000
FIGURE 5-2 Relative incidence and estimated annual new diagnoses of common lym-
phohematopoietic cancer subtypes in the United States. Abbreviations: ALL, acute lym-
phoblastic leukemia; AML, acute myeloid leukemia; CLL, chronic lymphoblastic leuke-
mia; CML, chronic myeloid leukemia; DLBCL, diffuse large B-cell lymphoma; and
LHP, lymphohematopoietic. Figure based on data from ACS (2010), LLS (2011), and
SEER (2010).
tissues. However, inasmuch as experimental evidence is absent, there is no di-
rect support for the hypothesis. Similarly, although recent evidence demon-
strates that normal hematopoietic precursors do indeed leave the bone marrow
and circulate as part of a daily circadian rhythm (Mendez-Ferrer et al. 2009),
studies have not shown that the cells are present in the nasal epithelium or
NALT, nor have they shown formaldehyde-induced effects in vivo. An addi-
tional hypothesis is that formaldehyde exposure at the port of entry induces sec-
ondary systemic effects, such as immune modulation or systemic inflammation,
both of which are associated with LHP cancers. However, given the lack of di-
rect data that could support those hypothetical modes of action, EPA could
shorten those sections of the draft substantially and note that the modes of action
remain uncertain.
Similarly, there is a paucity of evidence of formaldehyde-induced LHP
cancers in animal models. EPA’s unpublished re-analysis of the Battelle chronic
inhaled formaldehyde experiments in mice and rats (Battelle Columbus Labora-
tories 1981), although intriguing, provides the only positive findings and thus
does not contribute to the weight of evidence of causality.
Study Identification
The draft IRIS assessment comprehensively presents studies available
through late 2009 that evaluate formaldehyde exposure and risk of LHP cancers.
The draft provides commentary on multiple studies that had negative and posi-
OCR for page 92
Systemic Health Effects 111
tive findings, cohorts that were the subject of multiple analyses or publications,
and meta-analyses. The emphasis on studies of occupational cohorts is appropri-
ate, given that they provide the most specific and detailed exposure assessment
that can be applied in risk assessments. The committee is not aware of any im-
portant studies that are missing from the analysis, although several relevant stud-
ies have been published since the draft was released (for example, Andersen et
al. 2010; Bachand et al. 2010; Lu et al. 2010; Schwilk et al. 2010). To make the
IRIS assessment as timely as possible, inclusion of the recent studies seems war-
ranted in the revision.
Study Evaluation
EPA’s review is extensive and covers in considerable detail a substantial
body of pertinent epidemiologic and toxicologic literature. The study evalua-
tions tend to be long narratives that provide substantial detail on reported find-
ings. The heterogeneity of LHP cancers is acknowledged as a complicating fac-
tor in assessing causation and ultimately in the cancer assessment.
However, there is no clearly articulated framework for establishing causa-
tion on the basis of the weight and strength of evidence. An a priori presentation
of the study selection criteria (for example, quality of exposure assessment, con-
trol of confounding variables, and statistical power) is also missing. Both the
framework and study selection criteria are critical for any determination of cau-
sation. For example, the concept of consistency of findings within and among
studies is not defined, so it is difficult to determine how studies with different
study populations, cancer incidence, and exposure measures were combined to
provide a consistent and conclusive determination of causality. As a result, the
conclusion of causation appears to be based on a subjective view of the overall
data. Given the limitations of the epidemiologic studies (particularly uncertain-
ties of exposure assessment, possible confounding by other pollutants, and reli-
ance on mortality rather than incidence data), a clear statement and consistent
use of the weight-of-evidence criteria would strengthen the conclusions. Addi-
tional explicit reference to the EPA Guidelines for Carcinogen Risk Assessment
(EPA 2005a) and the Supplemental Guidance for Assessing Susceptibility from
Early-Life Exposure to Carcinogens (EPA 2005b) or other guidelines or prece-
dent for assessing the quality and importance of studies is recommended.
The absence of a causation framework is especially problematic for the
individual LHP cancers, given the highly variable epidemiologic literature and
the high uncertainty of mode of action. Important differences exist in the re-
ported findings of the most influential studies—of UK (Coggon et al. 2003) and
U.S. (Beane-Freeman et al. 2009) industrial cohorts, the National Institute for
Occupational Safety and Health garment workers cohort (Pinkerton et al. 2004),
and U.S. embalmers (Hauptmann et al. 2004). The differences should be dis-
cussed and weighed, specifically as to how they were taken into account in
EPA’s determinations of causality. For example, in the highly influential Na-
OCR for page 92
112 Review of EPA’s Draft IRIS Assessment of Formaldehyde
tional Cancer Institute (NCI) cohort study (Beane-Freeman et al. 2009), the
strength and specificity of the exposure-response associations varied considera-
bly over the period in which the cohort was followed. In addition, the reliance
on the peak-exposure metric to determine causality in that study rather than the
more conventional dose metric of cumulative exposure should be further justi-
fied, particularly in the absence of established modes of action.
Hazard Identification and Use of EPA Guidelines
The hazard identification concluded that there is a causal association be-
tween formaldehyde exposure and mortality from all LHP cancers, all leukemias
as a group, myeloid leukemias, Hodgkin lymphoma, and multiple myeloma. As
noted earlier, the committee strongly discourages the use of the grouping “all
LHP cancers,” given the biologic heterogeneity within this group. For the other
groupings, the committee finds that the conclusions of causality are not ade-
quately supported by the current narrative. Further discussion of LHP subtype
diagnosis in various studies would aid in comparison of findings. Sections cov-
ering all leukemias and myeloid leukemias are adequate in depth but would
benefit from a clearer synthesis of the data and more explicit reference to guide-
lines or precedents for evaluating evidence when there are notable differences in
data quality and conflicting results among studies. The committee recommends
caution on EPA’s part in using meta-analyses performed by others to assess cau-
sality or to quantify effects. Meta-analysis can be a valuable method for summa-
rizing evidence but can also be subject to variable interpretations depending on
how literature is selected and reviewed and data analyzed. Given the conflicting
conclusions of published meta-analyses of formaldehyde and LHP cancers (see,
for example, Zhang et al. 2009; Bachand et al. 2010; Schwilk et al. 2010), EPA
is encouraged to perform its own meta-analysis if the agency chooses to use
meta-analysis as a tool to assess causation.
Study Selection for Calculation of Unit Risk
As articulated by EPA, few studies can be used to calculate risk estimates.
Regardless, the selection and use of the NCI cohort (Beane-Freeman et al. 2009)
should be further justified. Indeed, interpretation of the study results is not
straightforward given that the findings differ from those of earlier analyses of
the same cohort and differ for peak, average, and cumulative formaldehyde ex-
posures. In the absence of evidence regarding exposure-disease mechanisms, as
in the case of formaldehyde and LHP cancers, cumulative exposure is typically
the default dose metric applied in epidemiologic analyses and risk assessment.
But the most significant results were found for peak exposures, which have the
greatest associated uncertainty. In view of the importance of this study, EPA
should clarify the basis of its interpretations of the results regarding the various
OCR for page 92
Systemic Health Effects 113
dose metrics and the various LHP cancers. Despite those concerns, the commit-
tee agrees that the NCI study is the most appropriate available to carry forward
for calculation of the unit risk.
Conclusions and Recommendations
The committee recommends that EPA address the following in the revi-
sion of the formaldehyde draft IRIS assessment:
Focus on the most specific diagnoses available in the epidemiologic
data, such as acute myeloblastic leukemia (International Classification of Dis-
eases [ICD] 205.0), chronic lymphocytic leukemia (ICD 204.1), and specific
lymphomas, such as Burkitt (ICD 200.2), Hodgkin (ICD 201), anaplastic large-
cell (ICD 200.6), and peripheral T-cell lymphoma (ICD 202.7). The committee
does not support consideration of the grouping “all LHP cancers” because this
grouping combines diverse cancers that are not closely related in cells of origin
and in other characteristics.
Evaluate existing studies and data with concise discussions of back-
ground and speculative hypotheses. The narratives in the draft IRIS assessments
are sometimes too long and unfocused.
Clarify how EPA determined weight and strength of evidence. The
draft assessment should be revised to discuss the benefits, limitations, and justi-
fications of using one exposure metric to determine causality and another to
calculate cancer unit risk. Because the draft assessment relies solely on epidemi-
ologic studies to determine causality, further discussion of the specific strengths,
weaknesses, and inconsistencies in several key studies is needed. As stated in
EPA’s cancer guidelines, EPA’s approach to weight of evidence should include
“a single integrative step after assessing all of the individual lines of evidence”
(EPA 2005a, Section 1.3.3, p. 1-11). Although a synthesis and summary are
provided, the process that EPA used to weigh different lines of evidence and
how that evidence was integrated into a final conclusion are not apparent in the
draft assessment and should be made clear in the final version.
Revisit arguments that support determinations of causality of specific
LHP cancers and in so doing include detailed descriptions of the criteria that
were used to weigh evidence and assess causality. That will add needed trans-
parency and validity to the conclusions.
If EPA decides to rely on meta-analysis as a tool to assess causation, it
should perform its own meta-analysis with particular attention to specific diag-
noses and to variables selected and combined for analysis. The contrasting con-
clusions of the published meta-analyses make it difficult to rely on conclusions
from any one analysis (see, for example, Zhang et al. 2009; Bachand et al. 2010;
Schwilk et al. 2010).
OCR for page 92
114 Review of EPA’s Draft IRIS Assessment of Formaldehyde
REFERENCES
ACS (American Cancer Society). 2010. Cancer Facts & Figures 2010. American Cancer
Society [online]. Available: http://www.cancer.org/acs/groups/content/@epide
miologysurveilance/documents/document/acspc-026238.pdf [accessed March
2, 2011].
Adams, D.O., T.A. Hamilton, L.D. Lauer, and J.H. Dean. 1987. The effect of formalde-
hyde exposure upon the mononuclear phagocyte system of mice. Toxicol.
Appl. Pharmacol. 88(2):165-174.
Andersen, M.E., H.J. Clewell III, E. Bermudez, D.E. Dodd, G.A. Willson, J.L. Campbell,
and R.S. Thomas. 2010. Formaldehyde: Integrating dosimetry, cytotoxicity,
and genomics to understand dose-dependent transitions for an endogenous
compound. Toxicol. Sci. 118(2):716-731.
Bachand, A.M., K.A. Mundt, D.J. Mundt, and R.R. Montgomery. 2010. Epidemiological
studies of formaldehyde exposure and risk of leukemia and nasophryngeal can-
cer: A meta-analysis. Crit. Rev. Toxicol. 40(2):85-100.
Battelle Columbus Laboratories. 1981. Final Report on a Chronic Inhalation Toxicology
Study in Rats and Mice Exposed to Formaldehyde. Prepared by Battelle Co-
lumbus Laboratories, Columbus, OH, for the Chemical Industry Institute of
Toxicology (CIIT), Research Triangle Park, NC. CIIT Docket No. 10922.
Beane-Freeman, L.E., A. Blair, J.H. Lubin, P.A. Stewart, R.B. Hayes, R.N. Hoover, and
M. Hauptmann. 2009. Mortality from Lymphohematopoietic malignancies
among workers in formaldehyde industries: The National Cancer Institute co-
hort. J. Natl. Cancer Inst. 101(10):751-761.
Coggon, D., E.C. Harris, J. Poole, and K.T. Palmer. 2003. Extended follow-up of a cohort
of British chemical workers exposed to formaldehyde. J. Natl. Cancer Inst.
95(21):1608-1615.Conrad, C.D. 2006. What is the functional significance of
chronic stress-induced CA3 dendritic retraction within the hippocampus? Be-
hav. Cogn. Neurosci. 5(1):41-60.
Dean, J.H., L.D. Lauer, R.V. House, M.J. Murray, W.S. Stillman, R.D. Irons, W.H.
Steinhagen, M.C. Phelps, and D.O. Adams. 1984. Studies of immune function
and host resistance in B6C3F1 mice exposed to formaldehyde. Toxicol. Appl.
Pharmacol. 72(3):519-529.
EPA (U.S. Environmental Protection Agency). 1991. Guidelines for Developmental Toxic-
ity Risk Assessment. EPA/600/FR-91/001. Risk Assessment Forum, U.S. Envi-
ronmental Protection Agency, Washington, DC. December 1991 [online]. Avail-
able: http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=23162 [accessed Nov.
24, 2010].
EPA (U.S. Environmental Protection Agency). 1996. Guidelines for Reproductive Toxic-
ity Risk Assessment. EPA/630/R-96/009. Risk Assessment Forum, U.S. Envi-
ronmental Protection Agency, Washington, DC. October 1996 [online]. Avail-
able: http://www.epa.gov/raf/publications/pdfs/REPRO51.PDF [accessed Nov.
24, 2010].
EPA (U.S. Environmental Protection Agency). 1998a. Health Effects Test Guidelines
OPPTS 870.7800 Immunotoxicity. U.S. Environmental Protection Agency
[online]. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ
-OPPT-2009-0156-0049 [accessed Feb. 22, 2011].
EPA (U.S. Environmental Protection Agency). 1998b. Guidelines for Neurotoxicity Risk
Assessment. EPA/630-95/001F. Risk Assessment Forum, U.S. Environmental
OCR for page 92
Systemic Health Effects 115
Protection Agency, Washington, DC. April 1998 [online]. Available:
http://www.epa.gov/raf/publications/pdfs/NEUROTOX.PDF [accessed Nov.
24, 2010].
EPA (U.S. Environmental Protection Agency). 2002. A Review of the Reference Dose
and Reference Concentration Processes. External Review Draft. EPA/630/P-
02/002A. Reference Dose/Reference Concentration (RfD/RfC) Technical
Panel, Risk Assessment Forum, U.S. Environmental Protection Agency, Wash-
ington, DC [online]. Available: http://www.epa.gov/raf/publications/pdfs/rfdr
fcextrevdrft.pdf [accessed Jan. 6, 2010].
EPA (U.S. Environmental Protection Agency). 2005a. Guidelines for Carcinogen Risk
Assessment. EPA/630/P-03/001F. Risk Assessment Forum, U.S. Environ-
mental Protection Agency, Washington, DC. March 2005 [online]. Available:
http://www.epa.gov/raf/publications/pdfs/CANCER_GUIDELINES_FINAL_3
-25-05.PDF [accessed Nov. 24, 2010].
EPA (U.S. Environmental Protection Agency). 2005b. Supplemental Guidance for As-
sessing Susceptibility from Early-Life Exposure to Carcinogens. EPA/630/R-
03/003F. Risk Assessment Forum, U.S. Environmental Protection Agency,
Washington, DC. March 2005 [online]. Available: http://www.epa.gov/ttn/at
w/childrens_supplement_final.pdf [accessed Nov. 24, 2010].
EPA (U.S. Environmental Protection Agency). 2010. Toxicological Review of Formal-
dehyde (CAS No. 50-00-0) – Inhalation Assessment: In Support of Summary
Information on the Integrated Risk Information System (IRIS). External Re-
view Draft. EPA/635/R-10/002A. U.S. Environmental Protection Agency,
Washington, DC [online]. Available: http://cfpub.epa.gov/ncea/iris_drafts/rec
ordisplay.cfm?deid=223614 [accessed Nov. 22, 2010].
Fitzgerald, R.E., M. Berres, and U. Schaeppi. 1988. Validation of a photobeam system
for assessment of motor activity in rats. Toxicology 49(2-3):433-439.
Hauptmann, M., J.H. Lubin, P.A. Stewart, R.B. Hayes, and A. Blair. 2004. Mortality
from solid cancers among workers in formaldehyde industries. Am. J. Epide-
miol. 159(12):1117-1130.
Holmström, M., and B. Wilhelmsson. 1988. Respiratory symptoms and pathophysiologi-
cal effects of occupational exposure to formaldehyde and wood dust. Scand. J.
Work Environ. Health 14(5):306-311.
Holness, D.L., and J.R. Nethercott. 1989. Health status of funeral service workers ex-
posed to formaldehyde. Arch. Environ. Health 44(4):222-228.
IARC (International Agency for Research on Cancer). 2006. Formaldehyde. Pp. 39-325
in Formaldehyde, 2-Butoxyethanol and 1-tert-Butoxypropan-2-ol. IARC
Monographs on the Evaluation of Carcinogenic Risks to Humans, Vol. 88.
Lyon, France: World Health Organization, International Agency for Research
on Cancer.
Kilburn, K.H. 1994. Neurobehavioral impairment and seizures from formaldehyde. Arch.
Environ. Health 49(1):37-44.
Kilburn, K.H., and A. Moro. 1985. Reproductive and maternal effects of formaldehyde
(HCHO) in rats. Fed. Proc. 44:535.
Kilburn, K.H., B.C. Seidman, and R. Warshaw. 1985. Neurobehavioral and respiratory
symptoms of formaldehyde and xylene exposure in histology technicians. Arch.
Environ. Health 40(4):229-233.
Kilburn, K.H., R. Warshaw, and J.C. Thornton. 1987. Formaldehyde impairs memory
equilibrium and dexterity in histology technicians: Effects which persist for
days after exposure. Arch. Environ. Health 42(2):117-120.
OCR for page 92
116 Review of EPA’s Draft IRIS Assessment of Formaldehyde
Krzyzanowski, M., J.J. Quackenboss, and M.D. Lebowitz. 1990. Chronic respiratory
effects of indoor formaldehyde exposure. Environ. Res. 52(2):117-125.
Lino dos Santos Franco, A., H.V. Domingos, A.S. Damazo, A.C. Breithaupt-Faloppa,
A.P. de Oliviera, S.K. Costa, S.M. Oliani, R.M. Oliveira-Filho, B.B. Vargaftig,
and W. Tavares-de-Lima. 2009. Reduced allergic lung inflammation in rats fol-
lowing formaldehyde exposure: Long term effects on multiple effector systems.
Toxicology 256(3):157-163.
LLS (The Leukemia & Lymphoma Society). 2011. Facts 2010-2011. The Leukemia &
Lymphoma Society [online]. Available: http://www.lls.org/content/nationalco
ntent/resourcecenter/freeeducationmaterials/generalcancer/pdf/facts [accessed
March 2, 2011].
Lu, K., L.B. Collins, H. Ru, E. Bermudez, and J.A. Swenburg. 2010. Distribution of
DNA adducts caused by inhaled formaldehyde is consistent with induction of
nasal carcinoma but not leukemia. Toxicol. Sci. 116(2):441-451.
Lyapina, M., G. Zhelezova, E. Petrova, and M. Boev. 2004. Flow cytometric determina-
tion of neutrophil burst activity in workers exposed to formaldehyde. Int. Arch.
Occup. Environ. Health 77(5):335-340.
Malek, F.A., K.U. Möritz, and J. Fanghänel. 2003a. A study on the effect of inhalative
formaldehyde exposure on water labyrinth test performance in rats. Ann. Anat.
185(3):277-285.
Malek, F.A., K.U. Möritz, and J. Fanghänel. 2003b. Formaldehyde inhalation and open
field behaviour in rats. Indian J. Med. Res. 118:90-96.
Malek, F.A., K.U. Möritz, and J. Fanghänel. 2003c. A study on specific behavioral ef-
fects of formaldehyde in the rat. J. Exp. Anim. Sci. 42(3):160-170.
Martin, W.J. 1990. A teratology study of inhaled formaldehyde in the rat. Reprod. Toxi-
col. 4(3):237-239.
McEwen, B.S. 2008. Central effects of stress hormones in health and disease: Under-
standing the protective and damaging effects of stress and stress mediators.
Eur. J. Pharmacol. 583(2-3):174-185.
Mendez-Ferrer, S., A. Chow, M. Merad, and P.S. Frenette. 2009. Circadian rhythms in-
fluence hematopoietic stem cells. Curr. Opin. Hematol. 16(4):235-242.
Morgan, K.T., D.L. Patterson, and E.A. Gross. 1986. Responses of the nasal mucociliary
apparatus of F-344 rats to formaldehyde gas. Toxicol. Appl. Pharmacol.
82(1):1-13.
Ohtsuka, R., Y. Shutoh, H. Fujie, S. Yamahuchi, M. Takeda, T. Harada, and K. Doi.
2003. Rat strain difference in histology and expression of Th1- and Th2- re-
lated cytokines in nasal mucosa after short-term formaldehyde inhalation. Exp.
Toxicol. Pathol. 54(4):287-291.
Ozen, O.A., M. Yaman, M. Sarsilmaz, A. Songur, and I. Kus. 2002. Testicular zinc, cop-
per and iron concentrations in male rats exposed to subacute and subchronic
formaldehyde gas inhalation. J. Trace Elem. Med. Biol. 16(2):119-122.
Pavlides, C., L.G. Nivón, and B.S. McEwen. 2002. Effects of chronic stress on hippo-
campal long-term potentiation. Hippocampus 12(2):245-257.
Pinkerton, L.E., M.J. Hein, and L.T. Stayner. 2004. Mortality among a cohort of garment
workers exposed to formaldehyde: An update. Occup. Environ. Med.
61(3):193-200.
Riedel, F., E. Hasenauer, P.J. Barth, A. Koziorowski, and C.H. Rieger. 1996. Formalde-
hyde exposure enhances inhalative allergic sensitization in the guinea pig. Al-
lergy 51(2):94-99.
OCR for page 92
Systemic Health Effects 117
Sadakane, K., H. Takano, T. Ichinose, R. Yanagisawa, and T. Shibamoto. 2002. Formal-
dehyde enhances mite allergen-induced eosinophilic inflammation in the mur-
ine airway. J. Environ. Pathol. Toxicol. Oncol. 21(3):267-276.
Saillenfait, A.M., P. Bonnet, and J. de Ceaurriz. 1989. The effects of maternally inhaled
formaldehyde on embryonal and foetal development in rats. Food Chem. Toxi-
col. 27(8):545-548.
Sarsilmaz, M., O.A. Ozen, N. Akpolat, I. Kus, and A. Songur. 1999. The histopathologic
effects of inhaled formaldehyde on Leydig cells of the rats in subacute period
[in Turkish]. J. Med. (Firat University Health Science) 13(1):37-40.
Schwilk, E., L. Zhang, M.T. Smith, A.H. Smith, and C. Steinmaus. 2010. Formaldehyde
and leukemia: An updated meta-analysis and evaluation of bias. J. Occup. En-
viron. Med. 52(9):878-886.
SEER (Surveillance Epidemiology and End Results). 2010. Estimated New Cancer Cases
and Deaths for 2010: All Races, By Sex. American Cancer Society, Surveil-
lance Epidemiology and End Results [online]. Available:
http://seer.cancer.gov/csr/1975_2007/results_single/sect_01_table.01.pdf [ac-
cessed March 2, 2011].
Sorg, B.A., and T. Hochstatter. 1999. Behavioral sensitization after repeated formalde-
hyde exposure in rats. Toxicol. Ind. Health 15(3-4):346-355.
Sorg, B.A., T.M. Bailie, M.L. Tschirgi, N. Li, and W.R. Wu. 2001. Exposure to repeated
low-level formaldehyde in rats increases basal corticosterone levels and en-
hances the corticosterone response to subsequent formaldehyde. Brain Res.
898(2):314-320.
Tarkowski, M., and P. Gorski. 1995. Increased IgE antiovalbumin level in mice exposed
to formaldehyde. Int. Arch. Allergy Immunol. 106(4):422-424.
Taskinen, H., P. Kyyronen, K. Hemminki, M. Hoikkala, K. Lajunen, and M.L. Lind-
bohm. 1994. Laboratory work and pregnancy outcome. J. Occup. Med.
36(3):311-319.
Taskinen, H.K., P. Kyyronen, M. Sallmen, S.V. Virtanen, T.A. Liukkonen, O. Huida,
M.L. Lindbohm, and A. Anttila. 1999. Reduced fertility among female wood
workers exposed to formaldehyde. Am. J. Ind. Med. 36(1):206-212.
Weisskopf, M., N. Morozova, E.J. O’Reilly, M.L. McCullough, E.E. Calle, M.J. Thun,
and A. Ascherio. 2009. Prospective study of chemical exposures and amyotro-
phic lateral sclerosis mortality. J. Neurol. Neurosurg. Psychiatry 80(5):558-561.
Zuena, A.R., J. Mairesse, P. Casolini, C. Cinque, G.S. Alemà, S. Morley-Fletcher, V.
Chiodi, L.G. Spagnoli, R. Gradini, A. Catalani, F. Nicoletti, and S. Maccari.
2008. Prenatal restraint stress generates two distinct behavioral and neuro-
chemical profiles in male and female rats. PLoS One 3(5):e2170.
Zhang, L., C. Steinmaus, D.A. Eastmond, X.K. Xin, and M.T. Smith. 2009. Formalde-
hyde exposure and leukemia: A new meta-analysis and potential mechanisms.
Mutat. Res. 681(2-3):150-168.