Document ym2K0jVzgXRyn7LDpJ688dy14

FILE NAME: Talc (TALC) DATE: 2000 Dec 1 DOC#: TALC175 DOCUMENT DESCRIPTION: Letter to Dr. Mary Wolfe, Duke University RE Comments on the Subcommittee's Consideration of Listing Talc in the 10th Report on Carcinogens Divt~,< i of Occupational & Environmental Medicine ID ec. u o u g Duke University Medical Center Department of Community & Family Medicine Division of Occupational & Environmental Medicine Box 3834 Durham, NC 27710 December 1, 2000 Tel: 919-286-5744 FAX: 919-286-5647 Dr. Mary S. Wolfe National Toxicology Program Board of Scientific Counselors Report on Carcinogens Subcommittee NIEHS, A3-07 Research Triangle Park, NC 27709 Re: Comments on the Subcommittee's Consideration of Listing M SB in the 10th Report on Carcinogens Dear Dr. Wolfe: My comments are being made on the behalf of the Art and Creative Materials Institute, a non-profit trade organization that represents the major manufacturers and importers of art materials in the United States. IB B is a common component of these art materials. 1 would like to address several issues discussed in the draft Report on Carcinogens: Background Document for Tale. Asbestiform and Non-Asbestiform. These comments are offered to the Report on Carcinogens Subcommittee with the expectation that this report can be strengthened if it addresses certain issues in more detail. I will comment on both on studies concerning both asbestiform and nonasbestiform tgf. Asbestiform Talc Definition: The draft report discusses the definition of asbestiform fibers. It would be strengthened if it includes NIOSH's definition of these fibers:. NIOSH (Kullman, et al. 1995) defines asbestiform habit as: "a specific type of mineral fibrosity in which the growth is primarily in one dimension and the crystals form naturally as long, flexible fibers. Fibers can be found in bundles that can be easily separated into smaller bundles or ultimately into fibrils." This definition is important since many of the fibers in asbestiform JtiJ are cleavage fragments. NIOSH's definition for asbestiform habit contrasts with their definition for the nonasbestiform habit: http / 72 !4 203 104/search?q=cache \Kzb3nEaXCsJ duk nd+Med+Talc+Pneiimoconiosis&hl=en&gl=us&ct=clnk&cd=6 (I of 8)4/12/2006 1 31 24 PM Division of Occupational & Environmental Mcdiunc "These minerals have ... crystal habits where growth proceeds in two or three dimensions instead of one dimension. When milled, these minerals do not break into fibrils but rather into fragments resulting from cleavage along the two or three growth planes. Particles formed by the comminution of these minerals are referred to as cleavage fragments." Respirable fiber size: Although the draft report notes that a respirable fiber has a diameter of 3-4 *m this is for fibers with a density of 1. 'laid has a specific gravity of 3 and, consequently the equivalent aerodynamic diameter of respirable fait fibers would be 1/3 of tins, on the order o f 1 m (Wylie, et al. 1993). This finding is particularly important in that the fibers in asbestifoi m talc are primarily widei than i m with only 10-11% of fibers in commercial talcs being <1 m in diameter. Fiber size and cancer risk: There are excellent animal models for the relationship between fiber dimension and risk of both mesothelioma and lung cancer. For mesothelioma risk, fibers with a dimension of <0.25 *m in diameter and >8 m long appear to present the greatest risk (Stanton, et al., 1981; Oehlert, 1991) with almost no risk presented by short fibers (Davis, et al. 1986) Most amphibole fibers in a asbestiform j j |i mine are shorter than 10 m (Kelse and Thompson, 1989) and would not be expected to present a risk of mesotheliomas. Similarly, lung cancer risk also depends on fiber dimensions. Based on asbestos inhalation studies, Berman et al (1995) found that potency for lung cancer rested with fibers that were longer than 10 m and less than 0.3 m in diameter. Their model found that fibers that were <10 *m long and had widths from 0.3-5.0 m were not associated with a lung cancer risk. Lippmann ( 1988) performed as similar analysis. He found that fiber retention drops rapidly as fiber diameter increases from 0.8 to 2.0 m. No lung cancel risk was associated with fiber length less than 5 *m. Lung cancer risk was associated with fibers with a diameter of 0.3-0.8 m and a substantial fraction >10 *m in length. Animal Studies: Although IARC considered a number of studies involving the carcinogenicity of fijl# in experimental animals, they did not have access to identification information concerning several of the fibrous talcs. This is particularly important because talcs form the Grouvenor p p |j| Company (GTC), the mine most studied for cancer risk, have been examined in a number of animal models and have been found to be non-carcinogenic. Stanton, et al. (1981) examined two asbestiform talcs from the Grouvenor talc district including one from GTC (Stanton j|8p #6) in their pleural implantation rat model. Neither of these talcs induced mesotheliomas although based on particle dimensions, a 60% incidence of mesotheliomas would have been expected with the GTC talc. Oehlert (1991) re-analyzed the Stanton data, breaking out potency assessments not only by particle size but by mineral type. When compared to asbestos, the author found that talcs were 1/135,000 as potent for causing pleural tumors. This re-analysis included both the asbestiform talcs and 5 non-asbestiform talcs studied by Stanton, et al. Smith, et al. (1979) also studied one GTC | | | i (FD14) in their hamster pleural mesothelioma model. This talc, as well as anothei talc containing amphibole fibers, was negative in their model. Wylie, et al. (1997) studied the FD14 i;g|f from the Smith et al. study in an in vitro system. It was not cytotoxic and did not induce cell proliferation. samples not containing quartz were not cytotoxic where asbestos was both cytotoxic and induced proliferation. Epidemiology: non-asbestiform amphiboles: The primary components of asbestiform talcs, other than gale, are cleavage fragments of anthophyllite and tremolite. Since exposure to these cleavage fragments may be a factor in cancer risk from exposure to asbestiform talc, a review of epidemiological studies of workers exposed to nonasbestiform amphiboles is in order and will strengthen this report. Kusiak et al (1991) looked at a cohort of 54128 gold and nickel miners with potential exposure to nonasbestiform amphibole fibers. They found an excess cancer risk in pre-1945 workers but no relationship between cancer excess and exposure to mineral fibers. The concluded that the excess was probably related to exposures to arsenic and radon decay products (radon daughters). Steenland and Brown (1995) studied 3328 gold miners from South Dakota. There was no significant increase in lung cancer r.sk in this cohort though there was evidence of excessive quartz exposure including elevated deaths from immunological diseases, renal disease and tuberculosis. The authors suggest that a slight excess in lung cancer rates might be related to the smoking habits of miners: they smoke more then the general population. Cooper et al (1992) studied 3444 taconite miners exposed to silica and nonasbestiform amphibole fibers. The standardized mortality rate (SMR) for lung cancer was less than expected at 67 and was not related to duration of employment, exposure level or latency. When Cooper, et al. eliminated those workers with less than 3 months o f employment from the analysis, the SM R for lung cancer actually decreased as duration of employment increased. Epidemiology: asbestiform tlB : The association between exposure to asbestiform tripe and lung cancer risk is primarily based on the findings of increased cancer risk in workers exposed to asbestiform J8J! in the Grouvenor WK district (GTD) of upstate New http i/72 14 203 104/seaich3q=cache vKzb3nEaXCsJ duk nd+Med+Talc+Pneumocomosis&hl=en&gl=us&ct=clnk&cd=6 (2 of 8)4/12/2006 1 31 24 PM Div'ai^n of Occupational & Environmental Medicine York. A more detailed description of these studies, as well as inclusion of the latest (Dezell et al, 1995) study would be in order. Kleinfeld, et al. (1967,1974) found a 10 pulmonary and pleural tumors among a study of all GTD workers. All cases occurred in workers who were exposed prior to the introduction of exposure control measures ca. 1945. Twenty-nine of the workers died of pneumoconioses, including 5 who died of a complication of quartz exposure, tuberculosis. This study had the short coming that it did not take into account exposures other then to talc, did not take into account smoking history and did not relate exposure levels to outcome. Recent data developed by NIOSH (1980) can be used to estimate respirable quartz exposures to workers in this study. NIOSH found that for the average dust exposure of 2.9 million particles per cubic foot (mppcf) in GTC mills, the average respirable quartz exposure was 11 g/m3 and that for the average dust exposure of 8.1 mppcf in the GTC mine the average quartz exposure was 12.4 g/ m3. Dust exposure measurements were made for GTD mines and mills in the Kleinfeld, et al. study. These exposures can be translated to average respirable quartz exposures as follows: j i ! 1 I \ i jMines: drilling [Mines' other M ills Pre-1945 M ppcf 818 129 69-278 Q artz ( g /m 3) 1250 190 260-1050 1945-1965 M ppcf 5 5-9 27-37 Quartz (g /m 3) 8 8-14 102-140 Exposure levels prior to 1945 were sufficiently high, in both mines and mills, to result in the pneumoconioses cases described above with quartz levels in air as great as 10 fold higher than today's permissible exposure limit for respirable quartz of 100 g/m3. Respirable quartz is a known human lung carcinogen, with elevated risks particularly when exposures are sufficient to result in silicosis. That respirable quartz exposures were a concern has been confirmed by autopsy studies performed by Dr. Jerrold Abraham of 8 GTD workers. Two of the 5 workers with a history of more than 20 years of | | J | mining had silicosis. The second study that has been used to implicate a risk between exposure to asbestiform and lung cancer is the NIOSH 1979 stud} of Grouvenor Title Company workers. GTC went into operation in the late 1940's using a wet drilling method that would have suppressed exposure to respirable quartz dust as noted in the above table. The NIOSH study has been criticized because of a number of short comings. It would be important to highlight these short comings since they have been addressed in later epidemiological studies of these workers. Specific concerns with this study included its small size; inclusion of all workers, including those that had only worked days; lack of assessment of the contribution of prior exposures; no study of exposure-lung cancer relationsh ps; and no adjustment for smoking effects (Brown, et al, 1983). Any prior mine work among GTC employees would have likely involved high level exposures to quartz dust. Stille and Tabershaw (1982) were able to nearly double the size of the cohort. They found that the SMR for lung cancel among workers who had only worked at GTC was less than expected (76) and that tuberculosis, a disease associated with silicosis, was a significant finding (SMR 680). This study did not correct for smoking history, exposure or identify non-GTC exposures that many have been a concern. Lamm, et al. (1988) presented a re-analysis of the Stille and Tabershaw (1982) data set in which the occupat onal histories of workeis dying of lung cancer were presented. 8 of 11 workers who died of lung cancer had worked in mines other than ta p mines or in quan les elsewhere than at GTC. The SMR for lung cancer in mill workers was 72 for those workers who had worked at least one year at GTC For those for workers who worked less than one year and had first worked to GTC 20-24 years prior to their death, the SMR for lung cancer was 1111. The latter group would have included workers with prior exposures to mine dust prior to the putting in place of dust control technologies. Gamble (1993) performed a nested case control study on NIOSH's second evaluation of 710 GTC workers (NIOSH, 1990) to addiess concerns of confounding. They found that when using fellow GTC workers as controls, all of the excess lung cancer risk could be ascribed to smoking. When looking at past exposures they found that essentially all f j |J exposure could be ascribed to work at GTC They were able to give more complete exposure histories for the lung cancer cases; 8 of the 22 cases had w o r k e d as d rille rs at m in e s o r quarries other than GTC and 17 had worked in metal mines prior to working at GTC. Work in mines would have been expected to be associated with exposure to either quartz dust (exposures would have likely been even higher in metal mines than in ta p mines because of quartz content of base rock) or radon daughters, a known cause of excess lung cancer risk in metal miners. That drillers may be at particular risk of quartz exposure has been noted by Rubino, et al. (1976) who found that dust generated from drilling operations m\ http H12 14 203 104/seaichiq=cache vKzb3nEaXCsJ duk nd+Med+TaIc+Pneumocomosis&hl=en&gI=us&ct=clnk&cd=6 (3 of 8)4/12/2006 I 31 24 PM Division of Occupational & Environmental Medicine contain up to 18% quartz, even though m g itself is relatively free from quartz. In metal mines, drilling dust can contain up to 39% quartz (McDonald, et al., 1978). Dezell, et al. (1995) further expanded the cohort to 818 workers and increased the latency time to an average of 21 years for GTC workers. They were able to address the concern that prior studies did not address incorporate an exposure-response analysis by estimating respirable dust exposures. When compared to past dust measurements, there was an excellent correlation between the two with a correlation coefficient of 0.78. They found no relationship between dust exposure at GTC and lung cancer. Increases in lung cancer were limited to workers hired prior to 1955 with deaths from non-malignant respiratory disease concentrated in this group as well. When adjusting for exposure they found an inverse relationship between lung cancer and exposure to all subjects, to those workers who were first employed prior to 1955 and to those workers who had worked at GTC for more than one year. The Gamble and Dezell. et al. studies discount the finding of an exposure-related risk of lung cancer for GTC workers with smoking and/or prior exposures to cancer-causing quartz dust or radon being likely contributors to the risk. Non-asbestiform Hflfc Lung overload: Your Committee's concern with cancer risk from exposure to non-asbestiform iB l rests in part on the finding of lung cancers in female rats exposed to greater than 18 mg/m3 of platy MM in an NTP assay. This assessment would be strengthened with a more complete discussion of overload of alveolar macrophage (AM) clearance (lung clearance) that can contribute to both lung cancer risk in rats and lung inflammation as seen in this study. When there is overload of lung clearance by inert particles, irreversible inflammation and even an increased cancer risk occurs This has been documented in rat exposure studies involving carbon black, diesel soot, titanium dioxide, toner and PVC spheres (Oberdorstei. 1995a). Such effects occur when particle deposition is such that AM can no longer keep the particle lung burden constant at a given dose. With sufficiently high exposures, lung clearance inhibition, and associated lung inflammation, is irreversible, even after exposure ceases (Bellman, et al, 1992). Inhibition of lung clearance and associated inflammation results in DNA and sister chromatid changes in lung epithelial cells. Lung inflammation is thought to be the reason for increased cancer risk in lung overload conditions. Although the Report discounts lung clearance as a mechanism for the finding of lung cancer in female rats in the NTP study, this overlooks the strong likelihood that lung overload was involved in the noted outcome. Oberdorster (1995b) found that lung clearance was markedly inhibited in both rats and mice in this study. Based upon the expected particle retention half lit'e, talc lung burden in rats was increased by a factor of 5-6.5 fold and in mice by a factor of 9.4 to 21.6 fold at 24 months. Without inhibition of lung clearance, no increase in talc lung burden would have been expected. Bronchiolar lavage studies done by NTP at this time confirmed the level of inflammation was what would be expected from the effects of lung clearance overload, not a specific toxic effect such as seen with respirable quartz. Goodman (1995), a member of the Scientific Board of Counselors evaluating this chronic t ; inhalation stud), concurred with Oberdorster that the maximum tolerated dose for this study was exceeded. He noted that platy talc was not genotoxic (Endo-Capron et al., 1990) and that the chronic toxicity and inflammation in female rats was substantially higher than in males (oi mice) where no tumors were noted. Animal studies: The NTP ||jS study is not supported by other studies of the carcinogenic potential of tp g in experimental systems. Stenback et al (1978) injected USP platy J ||J into the trachea of hamsters and found no respiratory tract tumors. Lesions seen were similar to those seen with treatment with iron dust. Endo-Capron, et al. (1990) injected fiber-free ||jg jn to the pleural space of 52 Sprague-Dawley rats. No pleural tumors occurred during their life span. Asbestos served as a positive control. Stanton, et al. ( 1981 ) examined the carcinogenicity of 7 talcs in their rat intrapleural assay. None of these talcs caused a higher frequency of tumors than seen in the study's control population. Oehlert (1991) re-analyzed the Stanton data, breaking out potency assessments not only by particle size but by mineral type. When compared to asbestos, the author found that talcs were 1/135,000 as potent for causing pleural tumors Five of these talcs were non-asbestiform. Epidemiological studies: The report discounts the follow up study of patients treated intrapleurally with talc (Research Committee of the British Thoracic Association and the Medical Research Council yEJJSEHSHESSUnit, 1979) b ecau se the le w as not identified and follow up intervals were less than 15 years. The pleural cavity appears to be particularly sensitive to the carcinogenic effects of minerals in the animal model. This "experiment" is, therefore, particularly cogent. Although MM tyPes were not identified, European Pharmacopea talcs which would have likely included talcs used for this purpose, have been analyzed (Paoletti, et al, 1984) and included both fibrous as well as platy talcs. Eighty-eight of the patients where followed for 15-30 years and 75 for 30-40 years, a duration http i n i 14 203 104/seaich3q=cache vKzb3nEaXCsJ duk nd+Med+Talc+Pneuinocomosis&hl=en&gl=us&ct=clnk&cd-6 (4 of 8)4/12/2006 1 31 24 PM Dtv'fcfton of Occupational & Environmental Medicine sufficiently long to have identified any cancer risk from such a procedure. Selvan, et al. (1979) found that the relative risk of lung cancel among millers exposed to platy m was 1.0 but elevated in miners. They discounted this association because miners can be exposed to radon daughters. Wergeland, et al. (1990) also found that cancer risk among jj|g millers working with fiber-free tale was not elevated They also explained a slight exposure level in the studied increase in mine was m lung cancer risk among miners as likely secondary to radon daughter 10 fold higher than in the mine in the Selvan, et al. study. exposure Radon daughtei In summary, the assessment of cancer risk of asbestiform and non-asbestiform l f e can be strengthened by: Addressing issues of risk associated with fiber size. Fiber-associated cancer risk is not seen with the small fiber lengths that predominate in the GTC mine and mill. Because exposures were qualitatively similar to those at other mines and mills m the region (Brown, et al. 1983) this relationship is particularly important for assessing the exposure-effecr relationships in the cohort studies on which your Committee bases there cancer risk concern. Including information on talc source in the description of 1 animal studies. A number of studies have been made of the GTD talcs, all negative for cancer risk. This finding is particularly important since the positive epidemiological studies for asbestiform talc are related to exposures to talc (and other) dust from this region. Including in the assessment a review of epidemiological studies of lung cancer risk (none) associated with exposure to nonasbestiform cleavage fragments. This is particularly cogent since the major fiber burden in GTD talcs is from such cleavage fragments. Including a discussion of exposure-effect relationships in the epidemiological assessment of asbestifoim talc cancer risk This is particularly pertinent since there is major confounding in the worker segment of these studies by not adjusting for risks of lung cancer from smoking and exposures to respirable quartz dust which has also been associated with human lung cancer risk A detailed assessment of exposure has not found a relationship between asbestiform IMg; exposure and increased lung cancer risk Including in the assessment a more detailed discussion of confounding by lung overload in the NTP talc inhalation study. Lung overload with inert particles is associated with lung inflammation and cancer risk. Significant lung overload occurred in both lats and mice in this study associated with both inflammation and lung cancer at the highest exposure level. That the cancer risk was likely associated with lung overload-related mechanisms needs to be addressed. Comparing the potency of jg( to asbestos in animal models. An updated assessment of the Stanton, et al. study of talcs found that asbestos was 135000 fold more potent than the talcs that they studied. These talcs included both asbestiform and non asbestiform talcs. Although asbestiform J| contains fibers, these do not appear to behave like asbestos. This animal model does not provide biological support for the NTP non-asbestiform Igjj study findings. Addressing the similarities between human J || pleurodesis and the rodent intrapleural model. The finding of no tumor risk in long term follow up of patients treated with pleurodesis lends support to the negative findings with lflc> in the animal model Respectfully submitted, http 072 14 203 1D4/searc)nq=cache vkzb3nEaXCsJ duk nd+Med+Talc+Pneumocomosis&hl=en&gl=us&ct=clnk&cd=6 (5 of 8)4/12/2006 1 31 24 PM i_MviMon ui uccupational & Environmental Medicine Woodhall Stopford, MD, MSPH References AbrahamJL. 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Wylie AG; Bailey KF; Kelse JW; Lee RJ. The importance of width in asbestos fiber carcinogenicity and its implications for public policy. Am Ind Hyg Assoc J 1993 May;54(5):239-52 Wylie AG; Skinner HC; Marsh J; Snyder H; Garzione C; Hodkinson D; Winters R; Mossman BT. Mineralogical features associated with cytotoxic and proliferative effects of fibrous f | j | and asbestos on rodent tracheal epithelial and pleural Msothlial cells.Toxicol Appl Pharmacol 1997 Nov; 147(1): 143-50 http .,72 14 203 104/search`>q=cache vKzb3nEaXCsJ duk nd+Med+Talc+Pneumoconiosis&hl=en&gl=us&ct=dnk&cd-6 (8 of 8)4/12/2006 1 3 1 24 PM