Document a4Kbg3JJkk8e7bNEmqozQ4KrM

"McCrea, Deborah" <mccrea@taftlaw .com> 11 /03/2009 12:19 PM To cc bcc Subject NCIC OPPT@EPA "Bilott, Robert A." <bilott@taftlaw.com> 11/03/2009 Letter To EPA Docket Center htaae- 39 t? Taft I Deborah McCrea / Legal Assistant Taft Stettinius & Hollister LLP 425 Walnut Street, Suite 1800 Cincinnati, Ohio 45202-3957 Tel : 513.381 .2838 - Fax: 513.381 .0205 www.taftlaw .com / mccrea@taftlaw .com cs Internal Revenue Service Circular 230 Disclosure: As provided for in Treasury regulations, advice (if any) relating to federal taxes that is contained in this communication (including attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. This message may contain information that is attorney-client privileged, attorney work product or otherwise confidential . If you are not an intended recipient, use and disclosure of this message are prohibited . If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. 1448_001 . pdf , p. 2 Taft/ Taft Stettinius & Hollister lLP 425 Walnut Street SuiteC1in8c0i0nn/aCtiinc/iCnlneavtei,laOnHd /4C5o2l0u2-m3b9u5s7/D/aTeylt:o5n1/3I.n3d8i1an.a2p8o3l8is/ F/aNxo:r5th1e3r.n38K1e.n0t2u0c5ky//wPwhwoe.ntiafxt/lBaew.icjionrgn ROBERT A. BILOTT 513-357-9838 bllott@taRlaw .coR+ November 3, 2009 FEDERAL EXPRESS EPA Docket Center, MC 2822T U .S . Environmental Protection Agency EPA West, Room 3334 1301 Constitution Avenue, NW Washington, D .C. 20004 Re: Submission to IRIS and AR-226 Database For PFOA/PFOS : ORD-2003-0016 EPA-HQ- To IRIS Database for PFOAIPFOS : In response to the Notice issued by USEPA on February 23, 2006, regarding USEPA's efforts to consider peIrnftleugorraotoecdtaRniosikcIancfiodrm(a"tPiFoOnAS"y)satnedm p(e"IrRfIlSu"o)r,o7o1ctFaened. Reg. sulfonate ("PFOS") within the 9333-9336 (Feb. 23, 2006), we are submitting the following additional information to USEPA for inclusion in that review, and for inclusion in the AR-226 database : 1 . Hoffman, K., et al., "Exposure to Polyfluoroaikyl Chemicals and Attention Deficit Hyperactivity Disorder in U .S . Children Aged 12-15 Years," 20 (6) Epidem. S70 (Nov. 2009) (ISEE 2009 Conference Abstract/Poster (Aug. 25-29, 2009)); and 2. Pinney, S.M., et al ., "Perfluorooctanoic Acid (PFOA) and Pubertal Maturation in Young Girls," 20 (6) Epidem. S80 (Nov. 2009) (ISEE 2009 Conference Abstract/Poster (Aug . 25-29, 2009)) . RAB :mdm Enclosures 11532535 .1 November 3, 2009 Page 2 cc: Gloria Post (NJDEP)(w/ encl.) (via U.S. Mail) Helen Goeden (MDH)(wl encl .) (via U.S . Mail) Lora Werner (ATSDR)(wl encl.) (via U.S . Mail) (W1405808 .1) Exposure to Polyfluoroalkyl Chemicals and Attention Deficit. . . : Epidemiology ., p. 4 Page 1 of 1 EpidemiolOgy: November 2009 - Volume 20 - Issue 6 - p S7o doi: io .io97/oi .ede.oooog629i8 .4o325.e9 Abstracts : ISEE 21st Annual Conference, Dublin, Ireland, August 25-29, 2009: Poster Presentations Exposure to Polyfluoroalkyl Chemicals and Attention Deficit Hyperactivity Disorder in U.S. Children Aged 12-15 Years Hofftman, Kate; Vieira, Veronica ; Webster, Thomas; White, Roberta 0 Abstract An abstract is unavailable. This article is available as HTML full text only. Qc 2009 Lippincott Williams & Wilkins, Inc. You currently do not have access to this article. You may need to: " Regi, er an &Q=nt. . Login ifyou are a registered subscriber . " Subscribe to this Journal , or . Purchase access to this article if you are not a current subscriber. . View thig article in Ovid if your institution subscribes to this journal. Note : If your society membership provides for full-access to this article, you may need to login on your society's web site first. http ://journals.lww.comlepidem/Citationl2009/11001lExposure to Polyfluoroalkyl Chemicals and.178.aspx 11/2/2009 0579 .htm , p. 5 Page 1 of l OS2.2 .6 Exposure to polyfluoroalkyl chemicals and attention deficit hyperactivity disorder In U.S. children aged 12-15 years. Kate Hoffman , Veronica Vieira, Thomas Webster, Roberta White Department of Environmental Health, Boston University School of Public Health, United States Background and Objective : Polyffuoroalkyl chemicals (PFCs) have been widely used in consumer products. Exposures in the U.S, and world populations are widespread . Associations between exposures to four common PFCs and parental report of diagnosis of Attention Deficit Hyperactivity Disorder (ADHD) were evaluated . Methods : Data were obtained from the National Health and Nutrition Examination Survey (NHANES) 1999-2000 and 2003-2004 for children aged 12-15. Parental report of a previous diagnosis by a doctor or healthcare professional of ADHD in the child was the outcome measure . PFOA, PFOS, PFNA, and PFHS levels were measured in serum samples from each child. The association between each PFC and ADHD was examined using smoothing, categories, and linear models. All analyses were adjusted for age, sex, race, maternal smoking during pregnancy, and environmental tobacco smoke . Confounding by variables such as lead and socioeconomic status was also assessed but associations were not altered . Results : Of the 586 children aged 12 to 15 in the sample, 51 were reported by their parents to have been diagnosed with ADHD . When PFOS was entered into analyses as a continuous predictor, a 1 .22 fold increased odds was observed for each 10 ygIL increase (95% CI 1 .03-1 .45). Similarly, compared to the first quartile of PFOS exposure, individuals in the fourth quartile were 1 .92 times more likely to have ADHD (95% CI 0.82-4 .51 ; p-value for trend=0 .039). There were also significant dose response relationships between PFHS and PFOA exposures and ADHD. For each pglL increase, the odds of ADHD increased 1 .06 and 1 .09 times respectively (95% CI 1 .02-1 .11 and 1 .00-1 .18). Similarly, children with higher PFNA levels were more likely to have ADHD (OR=1 .33 for NgIL increase; 95% CI 0.911 .95). Conclusions : These results are consistent with an affect of PFCs on ADHD risk. Follow-up of these cross-sectional data with cohort studies is needed . https:llisee.conference-services .net/reports/templatelonetextabstract .xml?xsl-templatelonetextabstract.xsl&c .. . 11/2/2009 Perfiiuorooctanoic Acid (PFOA) and Pubertal Maturation in You . .. : Epidemiology p. 6 Page 1 of 1 Epidemiology : November 2009 - Volume 20 - Issue 6 - p S8o doi: 1o.1o97/oi .ede.oooo362949-3o847~cb Abstracts : ISEE 21st Annual Conference, Dublin, Ireland, August 25-29, 2009: Poster Presentations Perfluorooctanoic Acid (PFOA) and Pubertal Maturation in Young Girls Pinney, Susan M.; Windham, Gayle C. ; Biro, Frank M.; Kushi, Larry H.; Yaghjyan, Lusine ; Calafat, Antonia; Kato, Kayoko; Succop, Paul; Brown, lVi Kathryn; Hernick, Ann; Bornschein, Robert 0 Abstract An abstract is unavailable . This article is available as HTML full text only. 2009 Lippincott Williams & Wilkins, Inc. You currently do not have access to this article. You may need to: " Register an agcount . " Lopg~in ifyou are a registered subscriber. . Subscribe to this Journal , or . Purchase access t4bis article if you are not a current subscriber. . View this article in Ovid if your institution subscribes to this journal. Note : If your society membership provides for full-access to this article, you may need to login on your society's web site first. httpa/journals .lww.com/epidem/Citation/2009/11001/Perfluorooctanoic Acid PFOA and Puberta1 .209.a... 11/2/2009 0'76~,htm p. 7 Page 1 of 1 OS10.5.4 Perfluorooctanoic acid (PFOA) and Pubertal Maturation In Young Girls Susan M. Pinnex 1, Gayle C. Windham2, Frank M. Biro3 ~4, Larry H . Kushis, Lusine Yaghjyanl, Antonia Calafats, Kayoko Katog, Paul Succop', M. Kathryn Browni, Ann Hernicki, Robert Bornschein' 'University of Cincinnati College of Medicine, Dept of Environmental Health, United States, ZEnvironmental Health Investigation Branch, California Department of Public Health, United States, 3University of Cincinnati College of Medicine, Dept. of Pediatrics, United States, 4Cincinnati Children's Hospital Medical Center, United States, 5Division of Research, Kaiser Permanente, United States, 6Division of Laboratory Sciences, National Center for Environmental Health, Centers f+or Disease Control and Prevention, United States Background : Polyfluoroalkyl compounds (PFCs) and their salts, such as perfluorooctanoic acid (PFOA), have been reported to change mammary gland structure and function in laboratory animals. We explored the relationship between serum PFOA concentration and timing of pubertal maturation in young girls . Methods : Within the NIH Breast Cancer and the Environment Research Centers (BCERC), we conducted a study of multiple environmental biomarkers, including PFOA and other PFCs in serum of young girls (age 6-7 years at entry) from two sites (N=689 girls). Pubertal staging (breast (B) and pubic hair (PH)) has been conducted by clinicians or trained research staff, every year or more frequently, for as long as four years. After calculating adjusted geometric means for all PFCs, we examined the relationship between PFOA serum concentration at the beginning of the study with body mass index (BMI) and pubertal Stage 2 at baseline and one year follow-up . Results: Detectable serum levels of five PFCs, including PFOA, were found in >95l0 of the girls. The PFOA median was 6.4 ng/ml (range < LOD 0.1 to 55 .9 ng/ml), with 24.9to having values above the 95th percentile for children 12-19 years (NHANES 2003-2004 population (8.6 nglml)) . At the follow-up visit, 28.3l0 of girls had reached Tanner stage B2+, 19.2% were PH2+ and 30.3% had a BMI percentile for age >85 . 1n analyses where serum PFOA was modeled as a continuous variable, we found a direct relationship with pubertal breast status and an inverse relationship with BMI percentile at the follow-up visit, with adjustment for age, race, site and caregiver education . Conclusions : It appears that PFOA acts as an endocrine disruptor although perhaps not by the usual mechanism . Although the relationship with BMI was inverse, there was a direct relationship with breast maturation . We continue to explore these complex relationships in models including other covarlates. 1.90 ON SNIViNOO https://isce.conference-services .netlreports/templatelonetextabatract .xml?xsl=template,/onetextabstract.xsl&c . . . 11/2/2009