## 6.5.1. REACH human

Authors: Theo Vermeire

Reviewers: Tim Bowmer

Learning objective:

You should be able to:

- outline how human risk assessment of chemicals is performed under REACH;
- explain the regulatory function of human risk assessment in REACH.

Keywords: REACH, chemical safety assessment, human, RCR, DNEL, DMEL

Human risk assessment under REACH

The REACH Regulation aims to ensure a high level of protection of human health and the environment, including the promotion of alternative methods for assessment of hazards of substances, as well as the free circulation of substances on the internal market while enhancing competitiveness and innovation. Risk assessment under REACH aims to realize such a level of protection for humans that the likelihood of adverse effects occurring is low, taking into account the nature of the potentially exposed population (including sensitive groups) and the severity of the effect(s). Industry therefore has to prepare a risk assessment (in REACH terminology: chemical safety assessment, CSA) for all relevant stages in the life cycle of the chemical, taking into account all risk management measures envisaged, and document this in the chemical safety report (CSR). Risk characterization in the context of a CSA is the estimation of the likelihood that adverse effect levels occur due to actual or predicted exposure to a chemical. The human populations considered, or protection goals, are workers, consumers and humans exposed via the environment. In risk characterization, exposure levels are compared to reference levels to yield “risk characterization ratios” (RCRs) for each protection goal. RCRs are derived for all endpoints (e.g. skin and eye irritation, sensitization, repeated dose toxicity) and time scales. It should be noted that these RCRs have to be derived for all stages in the life-cycle of a compound.

Environmental exposure assessment for humans

Humans can be exposed through the environment directly via inhalation of indoor and ambient air, soil ingestion and dermal contact, and indirectly via food products and drinking water (Figure 1). REACH does not consider direct exposure via soil.

Figure 1. Main exposure routes considered in REACH for environmental exposure of humans.

In the REACH exposure scenario, assessment of human exposure through the environment can be divided into three steps:

1. Determination of the concentrations in intake media (air, soil, food, drinking water);
2. Determination of the total daily intake of these media;
3. Combining concentrations in the media with total daily intake (and, if necessary, using a factor for bioavailability through the route of uptake concerned).

A fourth step may be the consideration of aggregated exposure taking into account exposure to the same substance in consumer products and at the workplace. Moreover, there may be similar substances, acting via the same mechanism of action, that may have to be considered in the exposure assessment, for instance, as a worst case, by applying the concept of dose or concentration addition.

The section on Environmental realistic scenarios (PECs) – Human explains the concept of exposure scenarios and how concentrations in environmental compartments are derived.

Hazard identification and dose-response assessment

The aim of hazard identification is to classify chemicals and to select key data for the dose-response assessment to derive a safe reference level, which in REACH terminology is called the DNEL (Derived No Effect Level) or DMEL (Derived Minimal Effect Level). For human end-points, a distinction is made between substances considered to have a threshold for toxicity and those without a threshold. For threshold substances, a No-Observed-Adverse Effect Level (NOAEL) or Lowest-Observed-Adverse-Effect Level (LOAEL) is derived, typically from toxicity studies with laboratory animals such as rats and mice. Alternatively a Benchmark Dose (BMD) can be derived by fitting a dose-response model to all observations. These toxicity values are then extrapolated to a DNEL using assessment factors to correct for uncertainty and variability. The most frequently used assessment factors are those for interspecies differences and those for intraspecies variability (see section on Setting safe standards). Additionally, factors can be applied to account for remaining uncertainties such as those due to a poor database.

For substances considered to exert their effect by a non-threshold mode of action, especially mutagenicity and carcinogenicity, it is generally assumed, as a default assumption, that even at very low levels of exposure residual risks cannot be excluded. That said, recent progress has been made on establishing scientific, ‘health-based’ thresholds for some genotoxic carcinogens. For non-threshold genotoxic carcinogens it is recommended to derive a DMEL, if the available data allow. A DMEL is a cancer risk value considered to be of very low concern, e.g. a 1 in a million tumour risk after lifetime exposure to the chemical and using a conservative linear dose-response model. There is as yet no EU-wide consensus on acceptable levels of cancer risk.

Risk characterization

Safe use of substances is demonstrated when:

• RCRs are below one, both at local and regional level. For threshold substances, the RCR is the ratio of the estimated exposure (concentration or dose) and the DNEL; for non-threshold substances the DMEL is used.

• The likelihood and severity of an event such as an explosion occurring due to the physicochemical properties of the substance as determined in the hazard assessment is negligible.

A risk characterization needs to be carried out for each exposure scenario (see Section on Environmental realistic scenarios (PECs) – Human) and human population. The assessment consists of a comparison of the exposure of each human population known to be or likely to be exposed with the appropriate DNELs or DMELs and an assessment of the likelihood and severity of an event occurring due to the physicochemical properties of the substance.

Example of a deterministic assessment (Vermeire et al., 2001) Exposure assessment Based on an emission estimation for processing of dibutylphthalate (DBP) as a softener in plastics, the concentrations in environmental compartments were estimated. Based on modelling as schematically presented in Figure 1, the total human dose was determined to be 93 ug.kg bw-1.
PEC-air | 2.4 | µg.m-3
PEC-surface water | 2.8 | µg.l-1
PEC- grassland soil | 0.15 | mg.kg-1
PEC-porewater agric. soil | 3.2 | µg.l-1
PEC-porewater grassl. soil | 1.4 | µg.l-1
PEC-groundwater | 3.2 | µg.l-1
Total Human Dose | 93 | µg.kgbw-1.d-1
Effects assessment The total dose should be compared to a DNEL for humans. DBP is not considered a genotoxic carcinogen but is toxic to reproduction and therefore the risk assessment is based on endpoints assumed to have a threshold for toxicity. The lowest NOAEL of DBP was observed in a two-generation reproduction test in rats and at the lowest dose-level in the diet (52 mg.kgbw-1.d-1 for males and 80 mg.kgbw-1.d-1 for females) a reduced number of live pups per litter and decreased pup weights were seen in the absence of maternal toxicity. The lowest dose level of 52 mg.kgbw-1.d-1 was chosen as the NOAEL. The DNEL was derived by the application of an overall assessment factor of 1000, accounting for interspecies differences, human variability and uncertainties due to a non-chronic exposure period. Risk characterisation The deterministic estimate of the RCR would be based on the deterministic exposure estimate of 0.093 mg.kgbw-1.d-1 and the deterministic DNEL of 0.052 mg.kgbw-1.d-1. The deterministic RCR would then be 1.8, based on the NOAEL. Since this is higher than one, this assessment indicates a concern, requiring a refinement of the assessment or risk management measures.

Additional reading

Van Leeuwen C.J., Vermeire T.G. (Eds.) (2007) Risk assessment of chemicals: an introduction. Springer, Dordrecht, The Netherlands, ISBN 978-1-4020-6102-8 (e-book), https://doi.org/10.1007/978-1-4020-6102-8.

Vermeire, T., Jager, T., Janssen, G., Bos, P., Pieters, M. (2001) A probabilistic human health risk assessment for environmental exposure to dibutylphthalate. Journal of Human and Ecological Risk Assessment 7, 1663-1679.