Application Of Uncertainty Factors Research Articles

Scientific Committee guidance on appraising and integrating evidence from epidemiological studies for use in EFSA's scientific assessments.

EFSA requested its Scientific Committee to prepare a guidance document on appraising and integrating evidence from epidemiological studies for use in EFSA's scientific assessments. The guidance document provides an introduction to epidemiological studies and illustrates the typical biases, which may be present in different epidemiological study designs. It then describes key epidemiological concepts relevant for evidence appraisal. This includes brief explanations for measures of association, exposure assessment, statistical inference, systematic error and effect modification. The guidance then describes the concept of external validity and the principles of appraising epidemiological studies. The customisation of the study appraisal process is explained including tailoring of tools for assessing the risk of bias (RoB). Several examples of appraising experimental and observational studies using a RoB tool are annexed to the document to illustrate the application of the approach. The latter part of this guidance focuses on different steps of evidence integration, first within and then across different streams of evidence. With respect to risk characterisation, the guidance considers how evidence from human epidemiological studies can be used in dose-response modelling with several different options being presented. Finally, the guidance addresses the application of uncertainty factors in risk characterisation when using evidence from human epidemiological studies.

A weight of evidence evaluation of the mode of action of isoeugenol

Isoeugenol is one of several phenylpropenoid compounds that is used as a fragrance, food flavoring agent and in aquaculture as a fish anesthetic. Carcinogenicity testing in rats and mice by NTP resulted in clear evidence of carcinogenicity (hepatic adenomas/carcinomas) in male mice only. A nongenotoxic threshold mode of action (MOA) is postulated for isoeugenol and is discussed considering the IPCS MOA and Human Relevance Framework. The weight of evidence indicates that isoeugenol is not genotoxic and that the carcinogenic outcome in male mice relates directly to the metabolism of individual compounds. Benchmark Dose (BMD) modeling was conducted to determine a Point of Departure (POD) and potential threshold of carcinogenicity. The results of the BMD evaluation for isoeugenol resulted in an estimated POD for carcinogenicity in the male mouse of 8 mg/kg with a lower limit of 4 mg/kg, representing a POD for the determination of an acceptable daily intake. With application of uncertainty factors, an ADI of 40 μg/kg is calculated. This daily dose in humans would be protective of human health, including carcinogenicity. A corresponding maximum residual level (MRL) of 3200 μg/kg fish is also estimated based on this POD that considers the threshold MOA.

Development of a framework for risk assessment of dietary carcinogens.

Although there are a number of guidance documents and frameworks for evaluation of carcinogenicity, none of the current methods fully reflects the state of the science. Common limitations include the absence of dose-response assessment and not considering the impact of differing exposure patterns (e.g., intermittent, high peaks vs. lower, continuous exposures). To address these issues, we have developed a framework for risk assessment of dietary carcinogens. This framework includes an enhanced approach for weight of evidence (WOE) evaluation for genetic toxicology data, with a focus on evaluating studies based on the most recent testing guidance to determine whether a chemical is a mutagen. Included alongside our framework is a discussion of resources for evaluating tissue dose and the temporal pattern of internal dose, taking into account the chemical's toxicokinetics. The framework then integrates the mode of action (MOA) and associated dose metric category with the exposure data to identify the appropriate approach(es) to low-dose extrapolation and level of concern associated with the exposure scenario. This framework provides risk managers with additional flexibility in risk management and risk communication options, beyond the binary choice of linear low-dose extrapolation vs. application of uncertainty factors.

Determination of Response Factors for Analytes Detected during Migration Studies, Strategy and Internal Standard Selection for Risk Minimization.

Migration studies are one of the few domains of pharmaceutical analysis employing wide-scope screening methodologies. The studies involve the detection of contaminants within pharmaceutical products that arise from the interaction between the formulation and materials. Requiring both qualitative and quantitative data, the studies are conducted using Liquid Chromatography or Gas Chromatography coupled to a mass spectrometer (LC-MS and GC-MS). While mass spectrometry allows wide-scope analyte detection and identification at the very low Analytical Evaluation Threshold (AET) levels used in these studies, MS detectors are far from "universal response" detectors. Regulation brings the application of uncertainty factors into the picture to limit the risk of potential analytes detected escaping report and further evaluation; however, whether the application of a default value can cover any or all relevant applications is still debatable. The current study evaluated the response of species usually detected in migration studies, generating a suitable representative sample, analyzing said species, and creating a strategy and evaluation mechanism for acceptable classification of the detected species. Incorporating novel methodologies, i.e., Design of Experiments (DoE) for Design Space generation, the LC-MS-based methodology is also evaluated for its robustness in changes performed.

Impacts of risk assessment data, assumptions, and methods: Considering the evidence for diacetyl and 2,3-pentanedione.

The articles published as part of the Frontiers in Public Health research topic, “Investigating exposures and respiratory health in coffee workers” present research findings that better characterize exposures to diacetyl and 2,3-pentanedione and inform our understanding of the health risks posed by these exposures. Although various research groups and organizations have conducted risk assessments to derive occupational exposure limits (OELs) for diacetyl, differences in the data used and assumptions made in these efforts have resulted in a wide range of recommended OELs designed to protect human health. The primary drivers of these differences include the decision to use data from human or animal studies in conducting a quantitative risk assessment, and the application of uncertainty factors (UF) to derive an OEL. This Perspectives paper will discuss the practical implications of these decisions, and present additional commentary on the potential role that the recent investigation of human exposures to relatively low concentrations of α-diketones, specifically diacetyl and 2,3-pentanedione, may play in supporting qualitative or quantitative human health risk assessments.

Inter-ethnic differences in CYP3A4 metabolism: A Bayesian meta-analysis for the refinement of uncertainty factors in chemical risk assessment

CYP3A4 is the major human cytochrome P450 isoform responsible for the metabolism of more than 50% of known xenobiotics. Here, inter-ethnic differences in CYP3A4 metabolism have been investigated through a systematic review of pharmacokinetic data for 15 CYP3A4 probe substrates and parameters reflecting acute (Cmax, oral route) and chronic exposure (clearance and area under the plasma concentration-time curve, oral and intravenous route). All data were extracted in a structured database and meta-analyses were performed using a hierarchical Bayesian model in the R freeware to derive parameter, route and population-specific variability distributions for CYP3A4 metabolism. Two different approaches were applied. 1) Inter-individual differences were quantified using North American healthy adults as a reference group to compare with European, Asian, Middle East, and South-American healthy adults and with ethnicity, elderly, children and neonates. 2) Intra-ethnic–specific variability distributions were derived without comparing to a reference group. Overall, subgroup-specific distributions for CYP3A4-variability provided the basis to derive CYP3A4-related uncertainty factors (UF) to cover 95th or 97.5th centiles of the population and were compared with the human default toxicokinetic UF (3.16). The results indicate that CYP3A4-related UFs in healthy adults were higher for chronic oral exposures (2.5–3.0, UF95 and UF97.5, 10 compounds) than for intravenous exposures (1.7–1.8, 2 compounds). All UFs were within the default TK UF. These distributions allow for: 1) the application of CYP3A4-related UFs in the risk assessment of compounds for which in vitro CYP3A4 metabolism evidence is available without the need for animal data; 2) the integration of CYP3A4-related variability distributions with in vitro metabolism data into physiologically based kinetic (PBK) models for quantitative in vitro to in vivo extrapolation (QIVIVE) and 3) the estimation of UFs in chemical risk assessment using variability distributions of metabolism.

“TKPlate”: A web-based platform for toxicokinetic modelling in food safety

CYP3A4 is the major human cytochrome P450 isoform responsible for the metabolism of more than 50% of known xenobiotics. Here, inter-ethnic differences in CYP3A4 metabolism have been investigated through a systematic review of pharmacokinetic data for 15 CYP3A4 probe substrates and parameters reflecting acute (Cmax, oral route) and chronic exposure (clearance and area under the plasma concentration-time curve, oral and intravenous route). All data were extracted in a structured database and meta-analyses were performed using a hierarchical Bayesian model in the R freeware to derive parameter, route and population-specific variability distributions for CYP3A4 metabolism. Two different approaches were applied. 1) Inter-individual differences were quantified using North American healthy adults as a reference group to compare with European, Asian, Middle East, and South-American healthy adults and with ethnicity, elderly, children and neonates. 2) Intra-ethnic–specific variability distributions were derived without comparing to a reference group. Overall, subgroup-specific distributions for CYP3A4-variability provided the basis to derive CYP3A4-related uncertainty factors (UF) to cover 95th or 97.5th centiles of the population and were compared with the human default toxicokinetic UF (3.16). The results indicate that CYP3A4-related UFs in healthy adults were higher for chronic oral exposures (2.5–3.0, UF95 and UF97.5, 10 compounds) than for intravenous exposures (1.7–1.8, 2 compounds). All UFs were within the default TK UF. These distributions allow for: 1) the application of CYP3A4-related UFs in the risk assessment of compounds for which in vitro CYP3A4 metabolism evidence is available without the need for animal data; 2) the integration of CYP3A4-related variability distributions with in vitro metabolism data into physiologically based kinetic (PBK) models for quantitative in vitro to in vivo extrapolation (QIVIVE) and 3) the estimation of UFs in chemical risk assessment using variability distributions of metabolism.

Bayesian methods for uncertainty factor application for derivation of reference values

In 2014, the National Research Council (NRC) published Review of EPA’s Integrated Risk Information System (IRIS) Process that considers methods EPA uses for developing toxicity criteria for non-carcinogens. These criteria are the Reference Dose (RfD) for oral exposure and Reference Concentration (RfC) for inhalation exposure. The NRC Review suggested using Bayesian methods for application of uncertainty factors (UFs) to adjust the point of departure dose or concentration to a level considered to be without adverse effects for the human population. The NRC foresaw Bayesian methods would be potentially useful for combining toxicity data from disparate sources—high throughput assays, animal testing, and observational epidemiology. UFs represent five distinct areas for which both adjustment and consideration of uncertainty may be needed. NRC suggested UFs could be represented as Bayesian prior distributions, illustrated the use of a log-normal distribution to represent the composite UF, and combined this distribution with a log-normal distribution representing uncertainty in the point of departure (POD) to reflect the overall uncertainty. Here, we explore these suggestions and present a refinement of the methodology suggested by NRC that considers each individual UF as a distribution. From an examination of 24 evaluations from EPA’s IRIS program, when individual UFs were represented using this approach, the geometric mean fold change in the value of the RfD or RfC increased from 3 to over 30, depending on the number of individual UFs used and the sophistication of the assessment. We present example calculations and recommendations for implementing the refined NRC methodology.

A global human health risk assessment for Decamethylcyclopentasiloxane (D5)

Decamethylcyclopentasiloxane (D5) is a low-molecular-weight cyclic siloxane used primarily as an intermediate in the production of several widely-used industrial and consumer products and intentionally added to consumer products, personal products and some dry cleaning solvents. The global use requires consideration of consumer use information and risk assessment requirements from various sources and authoritative bodies. A global “harmonized” risk assessment was conducted to meet requirements for substance-specific risk assessments conducted by regulatory agencies such as USEPA's Integrated Risk Information System (IRIS), Health Canada and various independent scientific committees of the European Commission, as well as provide guidance for chemical safety assessments under REACH in Europe, and other relevant authoritative bodies. This risk assessment incorporates global exposure information combined with a Monte Carlo analysis to determine the most significant routes of exposure, utilization of a multi-species, multi-route physiologically based pharmacokinetic (PBPK) model to estimate internal dose metrics, benchmark modeling to determine a point of departure (POD), and a margin of safety (MOS) evaluation to compare the estimates of intake with the POD. Because of the specific pharmacokinetic behaviors of D5 including high lipophilicity, high volatility with low blood-to-air partition coefficients and extensive metabolic clearance that regulate tissue dose after exposure, the use of a PBPK model was essential to provide a comparison of a dose metric that reflects these processes. The characterization of the potential for adverse effects after exposure to D5 using a MOS approach based on an internal dose metric removes the subjective application of uncertainty factors that may be applied across various regulatory agencies and allows examination of the differences between internal dose metrics associated with exposure and those associated with adverse effects.

The Scientific Basis of Uncertainty Factors Used in Setting Occupational Exposure Limits

The uncertainty factor concept is integrated into health risk assessments for all aspects of public health practice, including by most organizations that derive occupational exposure limits. The use of uncertainty factors is predicated on the assumption that a sufficient reduction in exposure from those at the boundary for the onset of adverse effects will yield a safe exposure level for at least the great majority of the exposed population, including vulnerable subgroups. There are differences in the application of the uncertainty factor approach among groups that conduct occupational assessments; however, there are common areas of uncertainty which are considered by all or nearly all occupational exposure limit-setting organizations. Five key uncertainties that are often examined include interspecies variability in response when extrapolating from animal studies to humans, response variability in humans, uncertainty in estimating a no-effect level from a dose where effects were observed, extrapolation from shorter duration studies to a full life-time exposure, and other insufficiencies in the overall health effects database indicating that the most sensitive adverse effect may not have been evaluated. In addition, a modifying factor is used by some organizations to account for other remaining uncertainties—typically related to exposure scenarios or accounting for the interplay among the five areas noted above. Consideration of uncertainties in occupational exposure limit derivation is a systematic process whereby the factors applied are not arbitrary, although they are mathematically imprecise. As the scientific basis for uncertainty factor application has improved, default uncertainty factors are now used only in the absence of chemical-specific data, and the trend is to replace them with chemical-specific adjustment factors whenever possible. The increased application of scientific data in the development of uncertainty factors for individual chemicals also has the benefit of increasing the transparency of occupational exposure limit derivation. Improved characterization of the scientific basis for uncertainty factors has led to increasing rigor and transparency in their application as part of the overall occupational exposure limit derivation process.

Method for adaptive decoding in case of information transmission in condition of influence of deliberate noise

It is proposed a method for increase of reliability of information transmission in wireless networks, functioning in conditions of influence of deliberate noise. The method is based on additional application of uncertainty factor in case of decision making in the turbo decoder in conditions of non-stationarity of the transmission channel. In a process of adaptive regulation of turbo code decoding iterations amount is modified for each data packet basing on dynamic calculation of uncertainty factor. Simulation results show increase of signal to noise ratio results in decoding iteration decrease, and information transmission reliability increase.

Update on a Pharmacokinetic-Centric Alternative Tier II Program for MMT-Part II: Physiologically Based Pharmacokinetic Modeling and Manganese Risk Assessment.

Recently, a variety of physiologically based pharmacokinetic (PBPK) models have been developed for the essential element manganese. This paper reviews the development of PBPK models (e.g., adult, pregnant, lactating, and neonatal rats, nonhuman primates, and adult, pregnant, lactating, and neonatal humans) and relevant risk assessment applications. Each PBPK model incorporates critical features including dose-dependent saturable tissue capacities and asymmetrical diffusional flux of manganese into brain and other tissues. Varied influx and efflux diffusion rate and binding constants for different brain regions account for the differential increases in regional brain manganese concentrations observed experimentally. We also present novel PBPK simulations to predict manganese tissue concentrations in fetal, neonatal, pregnant, or aged individuals, as well as individuals with liver disease or chronic manganese inhalation. The results of these simulations could help guide risk assessors in the application of uncertainty factors as they establish exposure guidelines for the general public or workers.

Proposal of new uncertainty factor application to derive tolerable daily intake

We propose new uncertainty factors (UFs) and a new subdivision of default factors in chemical risk assessment using a probabilistic approach based on the latest applicable information. Rounded values of 150 for mice, 100 for hamsters and rats, and 40 for rabbits, monkeys and dogs for inter- and intra-species differences (UF AH) were derived from the probabilistic combination of two log-normal distributions. Further calculation of additional UFs when chronic data (UF S) or NOAEL (UF L) are lacking was conducted using available log-normal distribution information. The alternative UF S and UF L values of 4 are considered to be appropriate for both cases where data are lacking. The default contributions of inter-species difference (UF A) and intra-species difference (UF H) to the UF AH of 100 for hamsters and rats as an example are considered to be 25 and 4, respectively. The UF A of 25 was subdivided into 25 0.6 (i.e., 7.0) for pharmacokinetics (PK) (UF A,PK) and 25 0.4 (i.e., 3.6) for pharmacodynamics (PD) (UF A,PD), and the UF H of 4 was evenly subdivided into 4 0.5 (i.e., 2) (UF H,PK and UF H,PD), to account for chemical-specific difference data between humans and laboratory animals for PK and/or PD. These default UFs, which come from actual experimental data, may be more appropriate than previous default UFs to derive tolerable daily intake values.

From the Editors

From the Editors

The French approach to deriving toxicity reference values: An example using reprotoxic effects

Following the French health and environment action plan, the French Agency for Environmental and Occupational Health and Safety set up a workgroup to standardise a method of deriving toxicity reference values (TRVs). Over the last few decades, there has been increasing concern about the effect of exposure to chemicals on reproductive function, leading the group to take an interest in reprotoxic effects. This article presents the recommendations of the workgroup regarding specific reprotoxic effects. Abnormal development of foetuses and infants, together with impairment of reproduction were considered to be critical effects. Where critical windows of exposure were concerned, quantitative analysis suggested the need for several types of toxicity reference value, as a function of exposure duration: reprotoxic effects may result from acute or chronic exposure at any time of life, whilst developmental effects may occur after exposure during the pregnancy or during the lactation period. The choice of a critical study is based on epidemiological or toxicological quality criteria. The working group recommends the use of the benchmark dose approach in estimating the critical dose. Finally, the working group considered the application of uncertainty factors typically used to take into account the variability between animal and human, between different individuals, and the availability of the data.

Development of a physiologically based pharmacokinetic (PBPK) model for methyl iodide in rats, rabbits, and humans

Methyl iodide (MeI) has been proposed as an alternative to methyl bromide as a pre-plant soil fumigant that does not deplete stratospheric ozone. In inhalation toxicity studies performed in animals as part of the registration process, three effects have been identified that warrant consideration in developing toxicity reference values for human risk assessment: nasal lesions (rat), acute neurotoxicity (rat), and fetal loss (rabbit). Uncertainties in the risk assessment can be reduced by using an internal measure of target tissue dose that is linked to the likely mode of action (MOA) for the toxicity of MeI, rather than the external exposure concentration. Physiologically based pharmacokinetic (PBPK) models have been developed for MeI and used to reduce uncertainties in the risk assessment extrapolations (e.g. interspecies, high to low dose, exposure scenario). PBPK model-derived human equivalent concentrations comparable to the animal study NOAELs (no observed adverse effect levels) for the endpoints of interest were developed for a 1-day, 24-hr exposure of bystanders or 8 hr/day exposure of workers. Variability analyses of the PBPK models support application of uncertainty factors (UF) of approximately 2 for intrahuman pharmacokinetic variability for the nasal effects and acute neurotoxicity.

Forum Series: The “Vision” for Toxicity Testing in the 21st Century: Promises and Conundrums

The ‘‘Forum’’ section of Toxicological Sciences is designed to include discussions and commentaries on relevant topics and timely issues facing toxicologists and to provide an interface between toxicology and public policy. While there are many topics and issues of interest to toxicologists, there are only a few that have the potential to have as great an impact on the science of toxicology, as the vision for ‘‘Toxicity Testing in the 21st Century’’ developed by the National Research Council (NRC) in 2007. In the present issue of the journal, we initiate the latest series of Forum articles which will focus on the promises and conundrums associated with the ‘‘Vision,’’ starting with an article by two members of the National Academies of Science (NAS) committee that developed it over the course of almost 3 years (Andersen and Krewski, 2009). The goal for the series of articles is to facilitate the communication of ideas and to promote open and balanced discussion to enhance the potential to realize the promises by identifying the challenges and conundrums associated with components of the ‘‘Vision.’’ Many of the methodologies routinely used today in the traditional approach to toxicity testing originated in the 1960s and 1970s and are based on high-dose studies in a variety of animal species. Besides the need for large numbers of animals, the current approach is expensive and time consuming. When the test results are used for human risk assessment, there are formidable challenges associated with dose and species extrapolation and with the application of uncertainty factors. Knowledge of toxicology and testing capabilities has increased dramatically in the last 40 years. Moreover, recent advances in systems biology, testing in cells and tissues, and related scientific fields offer the potential to fundamentally change the way that chemicals are tested for the risks that they may pose to humans. In 2004, the U.S. Environmental Protection Agency and the National Institutes of Environmental Health Sciences contracted with the NAS to establish a committee that would develop strategies to (1) increase the number of chemicals that could be tested, (2) decrease the cost of testing, and (3) increase the ability to determine the human risks of chemical environmental exposure. The NAS Committee completed their assignment in 2007, having published an interim report in 2006, and released the final report on 12 June 2007 (NRC, 2007). The report outlines four options for future toxicity testing strategies and, ultimately, offers a new approach that would rely less heavily on animal studies and, instead, focus on in vitro methods that evaluate chemicals’ effects on biological processes using cells, cell lines, or cellular components, preferably of human origin. This new vision and strategy for toxicity testing in the 21st century would be less expensive and less time consuming than the current approach. The vision would be based primarily on human biology instead of animal biology and would require anywhere between substantially fewer animals and virtually no animals. The vision would be based on measuring perturbations of toxicity pathways as opposed to changes in apical end points and would, thus, make far greater use of advances in mechanistic studies. Finally, because the vision will be based on high-throughput in vitro and in silico screens, a much broader range of doses can be characterized. As noted in the perspective from Andersen and Krewski (2009), ‘‘this vision for toxicity testing is built on defining dose-response relationships for toxicity pathway perturbations that would be expected to lead to adverse health outcomes, if the perturbations were maintained in vivo at a sufficient level of intensity and for a period of sufficiently long duration.’’ There are clear promises associated with components of the vision, which in many ways are natural extensions of the evolution of toxicology science—including the commitment to the three Rs: replacement, reduction, and refinement and the desire to integrate state-of-the-art mechanistic, modeling, and risk assessment approaches. However, to fully implement the vision, there are also challenges to be identified and obstacles to be overcome. The reliance on cell-based systems and in vitro methods present the long-debated problems with this approach, including the role of metabolism, the ability to extrapolate 1 For correspondence via E-mail: mholsapple@ilsi.org. Fax: (202) 659-3617.

Proposal of new uncertainty factor application to derive tolerable daily intake

Proposal of new uncertainty factor application to derive tolerable daily intake

Deriving Uncertainty Factors for Threshold Chemical Contaminants in Drinking Water

Uncertainty factors are used in the development of drinking-water guidelines to account for uncertainties in the database, including extrapolations of toxicity from animal studies and variability within humans, which result in some uncertainty about risk. The application of uncertainty factors is entrenched in toxicological risk assessment worldwide, but is not applied consistently. This report, prepared in collaboration with Health Canada, provides an assessment of the derivation of the uncertainty factor assumptions used in developing drinking-water quality guidelines for chemical contaminants. Assumptions used by Health Canada in the development of guidelines were compared to several other major regulatory jurisdictions. This assessment has revealed that uncertainty factor assumptions have been substantially influenced by historical practice. While the application of specific uncertainty factors appears to be well entrenched in regulatory practice, a well-documented and disciplined basis for the selection of these factors was not apparent in any of the literature supporting the default assumptions of Canada, the United States, Australia, or the World Health Organization. While there is a basic scheme used in most cases in developing drinking-water quality guidelines for nonthreshold contaminants by the jurisdictions included in this report, additional factors are sometimes included to account for other areas of uncertainty. These factors may include extrapolating subchronic data to anticipated chronic exposure, or use of a LOAEL instead of a NOAEL. The default value attributed to each uncertainty factor is generally a factor of 3 or 10; however, again, no comprehensive guidance to develop and apply these additional uncertainty factors was evident from the literature reviewed. A decision tree has been developed to provide guidance for selection of appropriate uncertainty factors, to account for the range of uncertainty encountered in the risk assessment process. Recent development of a series of “decision trees” by WHO to derive chemical specific adjustment factors for inter- and intraspecies variability may present an opportunity for a more systematic approach for the identification of evidence-based uncertainty factors.

Toxicology of Micronutrients: Adverse Effects and Uncertainty

The establishment of safe upper intake levels for micronutrients must consider the intake-response relations for both deficiency and toxicity. Limited data are available on the toxicities of most micronutrients, and few studies that meet the criteria considered essential for the risk assessment of other chemicals in food, such as pesticides and food additives, have been performed. In some cases, the application of large uncertainty factors, which are used to establish the amount of a chemical that would be safe for daily intake throughout life, could result in nutritionally inadequate intakes of micronutrients. As a consequence, lower than normal uncertainty factors have been applied to determine safe or tolerable intakes of many micronutrients. There is no clear scientific rationale, on the basis of the metabolism and elimination of micronutrients or the nature of the adverse effects reported for high intakes, for the use of reduced uncertainty factors for micronutrient toxicity. A review of recent evaluations of selected vitamins and minerals shows little consistency in the application of uncertainty factors by different advisory groups, such as the Institute of Medicine in the United States and the Scientific Committee on Foods in the European Union. It is apparent that, in some cases, the uncertainty factor applied was selected largely to give a result that is compatible with nutritional requirements; therefore, the uncertainty factor represented part of risk management rather than hazard characterization. The usual risk assessment procedures for chemicals in food should be revised for micronutrients, so that the risks associated with intakes that are too low and too high are considered equally as part of a risk-benefit analysis.