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Ann. occup. Hyg., Vol. 46, No. 6, pp. 560, 2002
© 2002 British Occupational Hygiene Society
Published by Oxford University Press
Letters to the Editor |
Reply
1 ExxonMobil Petroleum and Chemical, Hermeslaan 2, B-1831 Machelen, Belgium; 2 Shell International Ltd, Shell Centre, London SE1 7NA, UK
We acknowledge the view expressed in the above letter by Tielemans et al. that only data of a reasonable quality ought to be included in exposure assessments in order to improve their overall certainty. But we also consider that all exposure information has a role to play in regulatory exposure assessments, even though the weight that would be assigned to poor-quality data is low. Specifically, low-grade exposure information may not be useful for quantifying estimates of exposure, but can and ought to be utilized to help in their qualitative interpretation. This distinction is important.
The process by which the risks of chemicals are assessed and managed, such as that used for marketed substances in the European Union (European Communities, 1994), is one that extends beyond just the need to develop quantitative estimates of exposures to hazardous chemicals. Consideration must also be given to how these estimates relate to the interpretation of dose–response relationships when predicting risk, and the confidence that might be assigned to such ‘risk estimates’ when seen in the context of practical experience. Whilst low-grade exposure information does not have a substantive role to play in estimating exposure, it does help in the practical interpretation of such estimates. It is perhaps for this reason that the EU process for the risk assessment of chemicals does not automatically discount low-grade data, but requires that ‘all available exposure-related information on the substance should be used’ (European Commission, 1996). But in recommending this, the EU also recognizes that ‘it is unlikely that...data will be of adequate quality to be used uncritically in exposure assessment’. These elements may, in some part, explain the nature of the findings shown in Table 1 of Tielemans et al.’s letter.
REFERENCES
European Commission. (1996) Technical guidance document in support of Commission Directive 93/67/EEC on Risk Assessment for New Notified Substances and Commission Regulation No. 1488/94 on Risk Assessment for Existing Substances. Luxemburg: Office for Official Publications of the European Communities.
European Communities. (1994) Council Regulation 1488/94 laying down the principles for the assessment of risks to man and the environment of existing substances in accordance with Council Regulation (EEC) no. 793/93. Official Journal; L161: 29 June.
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