Risk assessment of dioxins and dioxin-like PCBs in food--comments by the German Federal Environmental Agency

Human health risk assessments for dioxins and dioxin-like PCBs (with the exception of the one by US-EPA) recommend health based exposure limits within the range of 1-4 pg WHO-TEQ/kg bw per day. As all humans are exposed to measurable levels of dioxins and related substances, the determination of the tolerated daily intake is a very significant decision and may influence limit values guiding risk reduction measures and target levels. The proposed TDI has to protect all human subpopulations. In the case of dioxin this is particularly important as the exposure of infants through breast-feeding may exceed the exposure of adults by one or two orders of magnitude. An overview of recently recommended limit values (WHO, SCF, JECFA) for PCDDs, PCDFs and dioxin-like PCBs using WHO-TEFs shows the common feature that the values were derived only from non carcinogenic endpoints. In November 2000 the Scientific Committee on Food of the European Commission published an 'Opinion of the SCF on the Risk Assessment of Dioxins and Dioxin-like PCBs in Food' SCF, Scientific Committee on Food 2000. Opinion of the SCF on the risk assessment of dioxins and dioxin-like PCBs in food. European Commission, Brussels, Adopted on November 2000 http://europa.eu.int/comm/food/fs/sc/scf/out78_en.pdf]. On the basis of this extensive review of data and experimental results the Committee recommended a temporary tolerable weekly intake (t-TWI) of 7 pg WHO-TEQ/kg bw. Only six months later the SCF carried out a re-evaluation of its t-TWI from November 2000. The reconsideration of 'pivotal studies' led to the situation that the re-assessment is now based only on rat studies which investigated only reproductive effects only on male offspring and, in addition, three of these studies are single dose studies at gestational day 15. Applying an overall uncertainty factor of 10 to the LOAEL derived estimated human daily intakes (EHDI) the SCF concluded that 14 pg/kg bw per week should be considered as a tolerable intake for 2,3,7,8-TCDD. The SCF stated that on a body weight basis, the dioxin intake of breast-fed infants has been estimated to be one to two orders of magnitude higher than the average adult intake. Recent German data suggest that the body burden of formerly breast-fed children aged 9-11 is still about 30% higher than those of their formula-fed age-mates. As breast-feeding has measurable benefits for neurological and immunological development, formula feeding cannot be recommended as an alternative to lower dioxin intake. So the only remaining way to lower the dioxin uptake is to drastically reduce the background exposure of the general population. It is acknowledged that any recommendation of a precise number for a TDI is flawed by uncertainties and the possibility of different weight being given to the studies of relevance. The determination of the TDI has influence on all regulatory limit values that are based on the TDI value. A higher TDI lowers the level of protection for humans. It is proposed by the German Federal Environmental Agency that the TDI should be reassessed in a process transparent to the public and on the basis of all relevant endpoints from animal experiments and human epidemiology, including the assessment of cancer risks.