Addressing combined effects of pesticides in the EU regulatory framework Prof Andreas Kortenkamp Brunel University London Info o session sess o o on cu cumulative u at e risk s assess assessment e t for o pesticides, EFSA Parma 11 Feb 2014 Legal requirements “… at present risk assessment on the combined effects of chemicals in a mixture is not commonly carried out out, nor required by most EU regulations.” SCHER, SCENIHR, SCCS (EU Scientific Committees on Health and Environmental Risks, Emerging and Newly Identified Health Risks, and Consumer Safety) (2011) Toxicity and Assessment of Chemical Mixtures. European Commission, DG Health & Consumers, Brussels 2 The long road to implementation 1996 US Food Quality Protection Act calls for CRA of pesticides with a common MoA 2002 US EPA Guidance on CRA of Pesticide Chemicals that have a Common MoA g p p , triazines,, chloroacaetanilides,, carbamates 2002–07 US EPA CRAs for organophosphates, 2005 EU Pesticide MRL regulation calls for the development and use of methodologies for CRA of pesticide residues (introduced upon initiative of the EP) 2005–08 2005 08 EFSA working groups on CRA established, Scientific Colloquium on CRA, Evaluation of existing methodologies, Recommendation of a tiered approach. 2009 Test result of a suggested methodology for the case of triazole fungicides. Conclusions: appropriate but not yet applicable on a routine basis… 2009 Requirement for mixture risk assessments established under the new EU PPP regulation: Active substances and plant protection products shall not have any harmful effects ff t on h human health, h lth taking t ki into i t accountt known k cumulative l ti and d synergistic i ti effects where the scientific methods accepted by the Authority to assess such effects are available,... (Article 4) Ongoing EFSA continues methodological work Dec 13 Scientific opinion on relevance of dissimilar mode of action and its appropriate application for cumulative risk assessment of pesticide residues in food 3 “Synergisms” – killing mosquito larvae Deltamethrin Deltamethrin + piperonylbutoxide Piperonylbutoxide inhibits cyp isoforms, but is not toxic to larvae on its own Fakoorziba et al. (2008) Food Environ Toxicol 24, 19 4 Prediction of mixture effects • Prediction of mixture effects when effects of components are known – applicable only if all p produce p effect of interest components • Assumption: chemicals act without interfering with each other • Effects can be p predicted by y using g dose (concentration) addition or independent action 5 Independent action • Stochastic principles • Additivityy expectation: effect multiplication • Si Simultaneous lt exposure: stochastic t h ti principles only fulfilled when components show different modes of action in inducing the same effect 6 Dose (concentration) addition • Agents A t behave b h lik like “dilutions” “dil ti ” off each h other th • Contribute to joint effect in proportion to their dose • Additivity expectation: addition of equieffective doses • Applied to combinations of similarly acting chemicals 7 Rat developmental toxicity Birth GD 7 Dosing PND 16 Dam Male offspring AGD PND 1 Retained nipples PND 13 Organ weights Malformations Malformations PND 47 PND 16 8 Three AR antagonists Hass et al. 2007 EHP 115 Suppl 1, 122 Dose addition 9 16 algal toxicants Faust et al. (2003) Aquat Toxicol 63, 43 Aclonifen 8-Azaguanine g Azaserine CCCP Chloramphenicol DTMAC Fenfuram Kresoxim-methyl Metalaxyl y Metazachlor Metsulfuron-methyl Nalidixic acid Norflurazon Paraquat Terbutylazim Triadimenol Conc addition Conc addition Independent action Independent action 10 Prediction of combination effects Dose addition provides good approximations of observed effects Retained nipples Vtg induction (fish) Micronuclei Androgen receptor antagonism 11 Synergism: penile malformations Christiansen et al. al 2009 EHP 117, 117 1839 Finasteride Vinclozolin DEHP Prochloraz 12 What is the correct concept? • DA or IA? • Often Often, DA and IA predictions are identical – irrespective of modes of action! • Are e hypotheses ypot eses about modes odes o of act action o a reliable basis for making choices? 13 Mixtures of anticancer drugs Different sites of action 120 corrected % ce ell killing g 100 IA 80 60 CA 40 20 0 -20 1e-6 1e-5 1e-4 1e-3 1e-2 1e-1 1e+0 1e+1 1e+2 1e+3 1e+4 1e+5 1e+6 Drug Concentration (µM) 14 Mixtures of aneugens Different sites and mechanisms of action Ermler et al. 2013, Arch Toxicol (in press) 15 What is the correct concept? • WHO / IPCS (2009): Use dose addition as a d f lt unless default, l th there iis evidence id tto th the contrary t • Dose addition is sufficiently conservative, but sometimes independent action predicts stronger mixture effects • Driver: slopes of dose-response curves 16 What should be grouped? Grouping criteria? • US EPA: Common mechanisms – similar chemical structures • US National Acad of Sciences (2008): Similar structures too narrow common adverse outcomes • Mechanisms: an unreliable g grouping p g criterion – information often not available • Data on common adverse outcomes also often not available • Data requirements for pesticide authorisation not geared towards making grouping decisions based on modes of action 17 When is a mixture safe? Dose addition Intake2 Intake1 + T l bl D Tolerable Daily il IIntake t k 1 <1 T l bl D Tolerable Daily il IIntake t k 2 Mixture effect is equal q to effect at TDI if every y component p is p present at TDI / n Independent action E 1,2,..n [(1-e1)( )(1-e2))...(1-e ( n)] 1 2 n = 1 - [( No mixture effect if all components are present at zero effect levels 100 agents with 1% effect: joint effect = 63% 100 agents with 0.1% effect: joint effect = 9.5% 18 When is a mixture safe? • Dose addition: dependent on number of components and sum of toxic units • Independent action: Are ADI always zero effect levels? – What about chemicals without ADI? • A matter for risk assessment • “…for Human Health effects, if the intended level of protection is achieved for each individual eac d dua substance, substa ce, the t e level e e of o concern co ce for o mixtures tu es o of d dissimilarly ss a y acting substances should be assumed as negligible.” • SCHER, SCENIHR, SCHER SCENIHR SCCS (EU Scientific Committees on Health and Environmental Risks Risks, Emerging and Newly Identified Health Risks, and Consumer Safety) (2011) Toxicity and Assessment of Chemical Mixtures. European Commission, DG Health & Consumers, Brussels 19 What is dissimilarity? Clear definitions not available • Reference cases for strictly dissimilarly acting mixtures are rare in mammalian toxicology • Only one example where independent action was shown to be applicable • The number of chemicals exceeds the number of available dissimilar modes of action 20 Mixture risk assessment methods Can we apply experimental mixture prediction concepts in risk assessment practice? Requirements of experimental assessment concepts (DA, IA): • • • The same endpoint was measured for single components and mixture D Dose-response d t for data f single i l components t and d mixture i t Allow predictions for a large range of effects Simplifications • Hazard Index (HI) • Point of Departure Index (PODI) • Relative Potency Factors (RPF) 21 Hazard index • • • EL - exposure level, l l e.g. iintake t k iin mg/kg/d /k /d AL - acceptable level, e.g. ADI or TDI EL and AL must be expressed in the same unit Simplifications: • AL not necessarily in relation to same endpoint • Different uncertainty factors may have been used to define AL • AL represent effect ff doses associated with the same (small ( or zero) effect 22 Example: Antiandrogens Kortenkamp and Faust 2010, Int J Androl 33, 463 23 Bottlenecks Information about exposures and reference doses must be available • Data ata gaps a are e tthe e rule u e – a vast ast number u be o of cchemicals e ca s a are e not toxicologically assessed • Approx 800 chemicals with ADI (TDI) vs 10,000, 20,000, ???? with food relevance • 134,000 chemicals pre-registered under REACH 24 Acknowledgements • Financial support from European Union: • ACE project • EDEN project j t • CONTAMED • UK FSA Contamed 25 The end Thank a you! you 26
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