Does the Emperor Have Any Clothes: Using Mechanistic Information or Doing Houdini Risk Assessments?

Abstract

Risk assessment research rarely quells controversy. Mega-mouse, and mega-rat, experiments contradicted a threshold for carcinogenesis, yet thresholds are still argued. High to low dose continuity of response from cigarette smoking to environmental tobacco smoke, and from occupational asbestos exposure to take-home asbestos, contradict thresholds in people. Nevertheless, mechanistic hypotheses allege “Houdini Risk Assessments”, which make risks disappear or allow industries to escape from protecting workers. Despite concerns for animal-to-human extrapolations, priority occupational exposures with sufficient or substantial evidence of carcinogenicity in people not addressed by new exposure limits include silica, sulfuric acid mist, chromates, diesel particulate matter, particulate matter generally, metalworking fluids, welding fume, and formaldehyde. “Houdini Risk Assessments” are exercises in “anti-hypothesis generation”: ignore selected tumor sites and types; ignore data from people (as with formaldehyde and diesel); choose the most resistant species in laboratory tests; select biochemical parameters in which the most resistant species resembles people; assume a mechanism that gives threshold or steep exposure response for carcinogenic effect; and reduce estimated people risk by the parameter ratio to the most resistant species. NORA research should focus on quantitative reconciliation of laboratory and epidemiology studies, and develop a counter “anti-hypothesis” generation research agenda for key exposure circumstances.