August,  1987
             820K88101
                                    CHLORAMBEN

                                  Health Advisory
                             Office of Drinking Water
                        U.S.  Environmental Protection Agency
I.  INTRODUCTION

        The Health  Advisory  (HA) Program, sponsored by the Office of Drinking
   Water (ODW),  provides  information on the health effects, analytical method-
   ology and treatment technology  that would be useful in dealing with the
   contamination of drinking water.  Health Advisories describe nonregulatory
   concentrations of drinking water contaminants at which adverse health effects
   would not be anticipated  to occur over specific exposure durations.  Health
   Advisories contain a margin of  safety to protect sensitive members of the
   population.

        Health  Advisories serve as informal technical guidance to assist Federal,
   State and local  officials responsible for protecting public health when
   emergency spills or contamination situations occur.  They are not to be
   construed as legally enforceable Federal standards.  The HAs are subject to
   change as new information becomes available.

        Health  Advisories are developed for one-day, ten-day, longer-term
   (approximately 7 years, or 10%  of an individual's lifetime) and lifetime
   exposures based  on data describing noncarcinogenic end points of toxicity.
   Health Advisories do not  quantitatively incorporate any potential carcinogenic
   risk from such exposure.   For those substances that are known or probable
   human carcinogens,  according to the Agency classification scheme (Group A or
   B),  Lifetime HAs are not  recommended.  The chemical concentration values for
   Group A or B carcinogens  are correlated with carcinogenic risk estimates by
   employing a  cancer potency (unit risk) value together with assumptions for
   lifetime exposure and  the consumption of drinking water.  The cancer unit
   risk is usually  derived from the linear multistage model with 95% upper
   confidence limits.   This  provides a low-dose estimate of cancer risk to
   humans that  is considered unlikely to pose a carcinogenic risk in excess
   of  the stated values.   Excess cancer risk estimates may also be calculated
   using the One-hit,  Weibull, Logit or Probit models.  There is no current
   understanding of the biological mechanisms involved in cancer to suggest that
   any one of these models is able to predict risk more accurately than another.
   Because each modvil is  based on  differing assumptions, the estimates that are
   derived can  differ by  several orders of magnitude.

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    Chloramben                                                    August,  1987

                                         -2-


II.  GENERAL INFORMATION AND  PROPERTIES

    CAS No.  133-90-4

    Structural  Formula;
                                          •COOH

                                  NH2  *CI

                           3-Amino-2-5-dichlorobenzoic  acid

    Synonyms

         0  Acp-m-728;  Ambiben;  Abiben;  Amibin;  Amoben; Chlorambed;  Chlorambene;
            NCI-C00055  ornamental weeder;  Ornamental weeder;  Vegaben;  Vegiven
            (U.S.  EPA,  1985).

    Uses

         0  Pre-emergent herbicide for weed  control  (Meister,  1983).



    Properties (U.S.  EPA, 1985;  CHEMLAB, 1985)
            Chemical Formula
            Molecular Weight               206.02
            Physical State (25°C)           Crystals
            Boiling Point                  —
            Melting Point                  200-201 "C
            Density                        —
            Vapor Pressure                 7 x 10~3  mm  Hg  (100°C)
            Specific Gravity               —
            Water Solubility (25°C)         700 mg/L
            Log Octanol/Water Partition    2.32
              Coefficient
            Taste Threshold
            Odor Threshold
            Conversion Factor
    Occurrence
         0  Samples were collected at 5 surface water locations and 188 ground
            water locations, and Chloramben was found in only 1 state.  The 85th
            percentile of all nonzero samples was 2.1 ug/L in surface water and
            1.7 ug/L in ground water sources.  The maximum concentration found
            was 2.3 ug/L in surface water and 1.7 ug/L in ground water (STORET,
            1987).

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     Chloramben                                                   August, 1987

                                          -3-


     Environmental Fate

          e  Sodium chloramben appears to be resistant to hydrolysis.  Limited
             studies indicate that there is no loss of phytotoxicity when aqueous
             solutions of chloramben are kept in the dark (Registrant CBI data).

          0  Photodegradation of aqueous solutions of sodium chloramben appears
             to occur readily in sunlight.  Total loss of phytotoxicity occurs in
             2 days.  Loss of phytotoxicity on dry soil is somewhat slower,  about
             30% in 48 hours (Registrant CBI data).

          0  Soil bacteria bring about a loss of phytotoxicity in sodium chloramben
             after several weeks.   It appears that this is due to a decarboxylation.
             The rate of reaction  appears to be independent of soil pH within the
             range of 4.3 to 7.5 (Registrant CBI data).

          0  The mobility of sodium chloramben is governed principally by its high
             solubility in water and its apparent limited strength of adsorption
             to soil particles.   It appears to easily leach down in most soil
             types by rainfall (Registrant CBI data).

          0  Probably all plants grown in contact with sodium chloramben take up
             the compound.  In some plants the subsequent movement of compound
             away from the roots is very slow, whereas in others it readily spreads
             throughout the plant.  The fate of chloramben in plants includes
             decomposition, a detoxifying conjugation which proceeds fairly rapidly,,
             and a detoxifying conjugation which goes slowly, if at all (Registrant
             CBI data).

          0  The methyl ester of chloramben acid appears to have the expected
             properties of a carboxylic acid ester.  It is apparently not hydrolysed
             after a short period  in contact with water at slightly acid pH values
             (5 to 6).  Bacteria-mediated hydrolysis appears to be quick:  approxi-
             mately 50% of the ester is converted to the free acid in about 1 week
             when in contact with  wet soil.  A subsequent and slower bacterial
             reaction, shown by  a  loss of phytotoxicity, is probably a decarboxy-
             lation, as with sodium chloramben (Registrant CBI data).

          0  The leaching behavior of the methyl ester is governed by its aqueous
             solubility, which is  much lower than that of the sodium salt (120 ppm
             and 250,000 ppm, respectively).  For a given rainfall the ester seems
             to leach down about 15% of the distance travelled by the sodium salt
             (Registrant CBI data).
III. PHARMACOKINETICS

     Absorption

          0  Chloramben is  rapidly  absorbed  from the gastrointestinal  tract of
             Sprague-Dawley female  rats  (Andrawes,  1984).   Based  on  radioactivity
             recovered in urine  (96.7%)  and  expired air (0.2%), about  97% of an
             oral dose (5 uCi/rat)  of  chloramben is absorbed.

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    Chloramben                                                   August,  1987
    Distribution
            And r awes  (1984)  reported  low levels (up to 0.5% of the administered
            dose)  of  chloramben  in  liver,  kidney,  lung, muscle,  plasma and red
            blood  cells  of rats  96  hours after a single oral dose (by gavage).
    Metabolism
            In rats dosed by gavage,  Andrawes (1984)  reported that the parent
            compound accounted  for 70%  of  the applied dose in 24-hour urine.

            Andrawes (1984)  identified  5 of 24 urinary metabolites:   3-amino-5-
            chlorobenzoic acid;  3-aminobenzoic acid;  2,5-dihydroxybenzoic acid;
            3,5-dihydroxybenzoic acid;  and 2,5-dichloroaniline.   Together, these
            constituted 1.4% of the administered dose.

            Metabolism of chloramben in rats proceeded through dechlorination,
            deamination,  decarboxylation and hydroxylation.  Metabolism through
            oxidative ring cleavage was negligible (Andrawes, 1984).
    Excretion
            Rats administered chloramben (5 uCi/rat)  by gastric intubation excreted
            over 99% of the dose within 3 to 4 days,  mostly within the first
            24 hours (Andrawes,  1984).   Approximately 96.7% was eliminated in the
            urine, with lesser amounts  in the feces (4.1%) and respiratory gases
            (0.2%).  Only 0.6% remained in the carcass after 3 to 4 days.
IV. HEALTH EFFECTS
    Humans
            No information was found in the available literature on the human
            health effects of chloramben.
    Animals
       Short-term Exposure

         0  Acute oral LD50 values for chloramben range from 2,101 mg/kg (Field,
            1980a) to 5,000 mg/kg (Field, 1978a) in rats; the acute dermal
            in rabbits has been reported to be >2,000 (Field, 1980b) or
            >5,000 mg/kg (Field, 1978b).
            Rees and Re (1978) reported an acute (1 hr) I/CSQ of >200 mg/L in rat
            inhalation studies.

            Keller (1959) fed male Holtzman Sprague-Dawley rats (10/dose) chloramben
            (100% a.i.) for 28 days in the diet at dose levels of 0, 1,000, 3,000
            or 10,000 ppm.  Assuming that 1 ppm in the diet of rats is equivalent
            to 0.05 mg/kg/day (Lehman, 1959), this corresponds to doses of 0,  50,
            150 or 500 mg/kg/day.  Body weights, food consumption, general appearance

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Ch^oramben  «                                                August, 1987

                                     -5-
        and behavior and histopathology were evaluated.  There were no statis-
        tically significant differences between the treated rats and untreated
        controls in any parameter measured.  Based on this information, a No-
        Observed-Adverse-Effect-Level (NOAEL) of 10,000 ppm (500 mg/kg/day),
        the highest dose tested,  was identified.

   Dermal/Ocular Effects

     0  Gabriel (1969)  applied chloramben (4 or 8 g/kg) to intact and
        abraded skin of 16 male albino rabbits (8/dose).  Test animals were
        observed for 14 days.   No evidence of skin irritation was observed
        under conditions of the study.

     0  In a study by Myers et al.  (1982), a 1.0% (w/w) chloramben sodium
        salt suspension produced  little or no sensitization reactions in male
        albino Hartley  guinea  pigs.

   Long-term Exposure

     0  In studies by Beliles  (1976),  weanling Golden Syrian hamsters
        (12/sex/dose) were administered technical chloramben (purity not
        specified) at dose levels of 0,  100, 1,000 or 10,000 ppm (reported to
        be equivalent to 0, 11, 115  or 1,070 mg/kg/day) in the diet for
        90 days.  Food  consumption,  body and organ weights and histopathology
        were evaluated.  No treatment-related adverse effects were reported
        for any parameter evaluated.  Based on this information, a NOAEL of
        10,000 ppm (1,070 mg/kg/day),  the highest dose tested, was identified.

     0  In an 18-month  feeding study (Huntingdon Research Center, 1978; cited
        in U.S. EPA,  1981), Crl:COBS CD-1 mice (50/sex/dose) were administered
        technical chloramben (purity not specified) at dietary levels of 0,
        100, 1,000 or 10,000 ppm. Assuming that 1 ppm in the diet of mice is
        equivalent to 0.15 mg/kg/day (Lehman, 1959), this corresponds to
        doses of about  0, 15,  150 and 1,500 mg/kg/day.  No compound-related
        effects were observed  in  terms of survival, general appearance,
        behavior or changes in body  weight.  Statistically significant
        (p <0.05) changes in organ weights included decreased liver weight in
        males at 100 ppm, decreased  kidney weight in males at 10,000 ppm, and
        decreased kidney weight in females at 10,000 ppm.  Since the values
        for these observations were  within normal ranges for this species and
        no trends were  established,  the organ-weight changes were not attributed
        to compound administration.   Histopathological examinations revealed
        alterations in  the livers of all treated mice.  The primary hepatocellular
        reaction was a  histomorphological hepatocellular alteration compatible
        with that observed in  enzyme induction.   The typical cellular changes
        included hepatocyte hypertrophy, increased nuclear size and chromatin
        content, and dense granular  eosinophilic cytoplasm.  Other changes
        included scattered foci of individual or small groups of degenerating
        hepatocytes,  hepatocyte vacuolation, cytoplasmic eosinophilic inclusions,
        and multiple focal small  granulomas.  Based on the reported hepatic
        effects, this study identifies  a Lowest-Observed-Adverse-Effect-Level
        (LOAEL) of 100  ppm (15 mg/kg/day).

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                                                          August,  1987
                                                       r
                                 -6-
  •   NCI  (1977)  administered  technical-grade  chloramben  (90  to  95% active
     ingredient) to Osborne-Mendel  rats  ( 50/sex/dose)  and  B6C3Fi  mice
     (50/sex/dose)  for  80 weeks at  dietary  levels  of  10,000  or  20,000 ppm.
     Assuming that  1 ppm in the diet of  rats  is  equivalent to 0.05 mg/kg/day
     and  1  ppm in the diet of mice  is  equivalent to 0.15 mg/kg/day (Lehman,
     1959), this corresponds  to doses  of 500  or  1,000 mg/kg/day for rats
     and  1,500 or 3,000 mg/kg/day for  mice.   Matched  controls consisted  of
     10 animals  per sex for each species.   Pooled  controls consisted of
     the  matched controls plus 75 rats/sex  and 70  mice/sex from similarly
     performed bioassays.  Body weights  and mortality did  not differ
     between control and treatment  groups for both species,  and the various
     (unspecified)  clinical signs observed  were  similar  in the  control and
     treatment groups for both species.   Based on this information, a
     NOAEL of 20,000 ppm  (1,000 mg/kg/day for rats and 3,000 mg/kg/day for
     mice), the highest dose  tested, was identified for  each species.

  0   In studies conducted by  Paynter et  al.  (1963), albino rats
     ( 35/sex/dose)  were administered chloramben  (97%  pure) in the diet for
     2 years at dose levels of 0, 100,  1,000  or  10,000 ppm.  Assuming that
     1  ppm in the diet  of rats is equivalent  to  0.05  mg/kg/day  (Lehman,
     1959), this corresponds  to doses  of 0,  5, 50 or  500 mg/kg/day.
     Untreated rats (70/sex/dose) were observed  concurrently.   The general
     appearance and behavior, growth,  food  consumption,  clinical chemistry,
     hematology and histbpathology  in  the treated  rats did not  differ
     significantly  from the untreated  controls.   Based on  this  information,
     a NOAEL of 10,000  ppm  (500 mg/kg/day),  the  highest  dose tested, was
     identified.

  e   Hazleton and Farmer  (1963) administered  technical chloramben (97%
     pure) in the feed  to 16  young  adult beagle  dogs  (4/sex/dose) for
     2 years at dietary levels of 0, 100, 1,000  or 10,000  ppm.   Assuming
     that 1 ppm in  the  diet of dogs is equivalent to  0.025 mg/kg/day
     (Lehman, 1959), this corresponds  to doses of 0,  2.5,  25 or 250 mg/kg/day.
     General appearance and behavior,  food  consumption,  body weight,
     hematology, biochemistry, urinalysis and histopathology of the treated
     dogs did not differ significantly from the  untreated  controls.  Based
     on this information, a NOAEL of 10,000 ppm  (250  mg/kg/day), the highest
     dose tested, was identified.

  0   Johnston and Seibold  (1979) administered technical  chloramben to
     Sprague-Dawley rats  for  2 years at  dietary  concentrations  of 0,
     100, 1,000 or  10,000 ppm.  Assuming that 1  ppm in the diet of rats  is
     equivalent to  0.05 mg/kg/day  (Lehman,  1959) this corresponds to doses
     of 0, 5, 50 and 500 mg/kg/day. No  compound-related effects were
     observed on any parameters measured including body  weight, food
     consumption, hematology, clinical chemistry,  urinalysis, gross
     pathology and  histopathology.   Based on this information,  a NOAEL of
     10,000 ppm (500 mg/kg/day), the highest dose tested,  was identified.

Reproductive Effects

  0   In a three-generation  study  (Gabriel,  1966),  three  groups  of albino
     rats (8 females and  16 males/dose)  were administered  0, 500, 1,500  or

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Chloramben                                                   August, 1987

                                     -7-
        4,500 ppm chloramben (purity not specified)  in the diet for 9 weeks
        prior to breeding,  during breeding and during weaning periods.
        Assuming that 1  ppm in the diet of rats is equivalent to 0.05 mg/kg/day
        (Lehman,  1959),  these dietary levels  correspond to doses of about 0,
        25,  75 or 225 mg/kg/day.   Untreated animals  served as controls.
        Following treatment,  various parameters were measured, including
        indices of fertility, gestation,  viability and lactation.   No adverse
        effects were reported in  any parameter measured.   Based on this
        information,  a NOAEL of 4,500 ppm (225 mg/kg/day), the highest dose
        tested, was identified for reproductive effects.

   Developmental Effects

     0   Beliles and Mueller (1976) administered technical chloramben (purity
        not specified) to pregnant CFE rats (20/dose)  by incorporation into
        the diets on days 6 through 15 of gestation.  No compound-related
        changes were seen among dams treated  at levels of 0,  500,  1,500 and
        4,500 ppm.  Assuming that 1 ppm in the diet  of rats is equivalent to
        0.05 mg/kg/day (Lehman, 1959), this corresponds to doses of about 0,
        25,  75 or 225 mg/kg/day.   Fetal mortality was increased, and data
        suggestive of decreased fetal skeletal development were observed in
        fetuses from dams treated at 4,500 ppm (225  mg/kg/day).  At 1,500 ppm
        (75 mg/kg/day),  there was no significant increase in embryo mortality;
        however,  there was  a generalized reduction in skeletal development.
        Fetuses of dams  treated with 500 ppm  (25 mg/kg/day) were similar in
        all respects to  those of  untreated control dams.   Based on this
        information,  a NOAEL of 4,500 ppm (225 mg/kg/day), the highest dose
        tested, was identified for maternal toxicity and teratogenicity.  The
        NOAEL for fetotoxicity was identified as 500 ppm (25 mg/kg/day).

     0   Holson (1984) conducted studies in which New Zealand White rabbits
        (24/dose) were administered chloramben (sodium salt,  83% a.i. by weight)
        by gavage at dose levels  of 0, 250, 500 or 1,000 mg/kg during days
        6 through 18 of  gestation.  A NOAEL of 1,000 mg/kg/day, the highest
        dose tested,  was identified, since the test  compound  did not produce
        maternal or fetal toxicity or teratogenic effects at any dose level
        tested.  Other end  points were not monitored.

   Mutagenicity

     0   Chloramben was found to be negative in several indicator systems for
        potential mutagenic activity, including several microbial  assays
        (Anderson et al., 1967; Eisenbeis et  al.,  1981; Jagannath, 1982), an
        in vivo bone marrow cytogenetic assay (Ivett,  1985) and primary rat
        hepatocytes unscheduled DNA synthesis test (Myhr and  McKeon,  1982).

     0   Results were positive for the in vitro cytogenic test using Chinese
        hamster ovary cells (Galloway and Lebowitz,  1982).

   Carcinogenicity

     0   In an 18-month feeding study (Huntingdon Research Center,  1978; cited
        in U.S. EPA,  1981),  CrlrCOBS CD-1  mice (50/sex/dose)  were  administered

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  Chloramben                                                   August,  1987

                                        -8-
           technical chloramben  (purity  not  specified) at dietary  levels  of 0,
           100,  1,000 or 10,000  ppm.  Assuming that  1 ppm in the diet  of  mice is
           equivalent to 0.15 mg/kg/day  (Lehman,  1959), this corresponds  to
           doses of about  0, 15,  150 and 1,500 mg/kg/day (Lehman,  1959).
           Hepatocellular  carcinomas (trabecular  type) were present  in 1/50 low-
           dose  and 1/50 high-dose males.  In no  case was vascular invasion or
           secondary spread of the nodular carcinoma masses observed.   Hepatocellular
           adenomas were present only in males as follows:  5/50 control,  2/50
           low-dose, 2/48  intermediate-dose  and 5/50 high-dose.  However,  due to
           a number of deficiencies in this  study (e.g., missing data,  significant
           tissue autolysis), no conclusion  can be made regarding  the  oncogenic
           potential of the test material.

        0   NCI  (1977) administered 10,000 or 20,000 ppm technical  chloramben
           (90  to 95% active ingredient)  in  the feed to Osborne-Mendel rats
           (50/sex/dose) and B6C3F1 mice (50/sex/dose) for 80 weeks  followed by
           up to 33 weeks  of postexposure observation.  Assuming that  1 ppm in
           the  diet of rats is equivalent to 0.05 mg/kg/day and 1  ppm  in  the
           diet of mice is equivalent to 0.15 mg/kg/day (Lehman, 1959), this
           corresponds to  doses  of 500 or 1,000 mg/kg/day for rats and 1,500 or
           3,000 mg/kg/day for mice.  Under  conditions of the study, no compound-
           related tumors  were reported  in male or female rats or  male mice.
           Hepatocellular  carcinomas were reported in female mice, but in a
           retrospective audit of this bioassay by Drill et al. (1^82), it was
           reported that the incidence of hepatocellular carcinomas  in both the
           low-dose and high-dose female mice was lower than the maximal
           incidence of corresponding tumors in historical groups.   It was
           concluded that  there  was no association between chloramben  and  the
           occurrence of hepatocellular  carcinomas under conditions  of the assay.
           However, since  exposure was for only 80 weeks, this study may  not
           have been adequate to detect  late-occurring tumors.

        0   Paynter et al.  (1963) reported no evidence of carcinogenic  activity
           in albino rats  (35/sex/dose)  that received chloramben (97%  pure) in
           the  diet for 2  years  at dose  levels of 0, 100, 1,000 or 10,000 ppm.
           Assuming that 1 ppm in the diet of rats is equivalent to  0.05  mg/kg/day
           (Lehman, 1959)  this corresponds to doses  of 0, 5, 50 or 500 mg/kg/day.

        0   Johnston and Seibold  (1979) reported no evidence of carcinogenic
           activity in Sprague-Dawley rats administered 0, 100, 1,000  or
           10,000 ppm technical  chloramben in the diet for 2 years.  Assuming
           that 1 ppm in the diet of rats is equivalent to 0.05 mg/kg/day (Lehman,
           1959), this corresponds to doses  of 0, 5, 50 or 500 mg/kg/day.   No
           compound-related effects were observed on any other parameters measured,
           including body  weight, food consumption,  hematology, clinical  chemistry,
           urinalysis, gross pathology and histopathology.


V. QUANTIFICATION OF TOXICOLOGICAL EFFECTS

        Health  Advisories  (HAs)  are generally determined for one-day,  ten-day,
   longer-term  (approximately 7  years) and lifetime  exposures if adequate data
   are available that identify a sensitive noncarcinogenic end point of toxicity.
   The HAs for  noncarcinogenic toxicants are derived using the following  formulas

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Chloramben                                                   August, 1987

                                     -9-
where:
              HA . (NOAEL or LOAEL) x (BW) „ 	 mg/L (	 ug/L)
                     (UF) x (    L/day)
        NOAEL or LOAEL = No- or Lowest-Observed-Adverse-Effect-Level
                         in rag/kg bw/day.

                    BW = assumed body weight of a child (10 kg) or
                         an adult (70 kg).

                    UF = uncertainty factor (10, 100 or 1,000), in
                         accordance with NAS/ODW guidelines.

             	 L/day = assumed daily water consumption of a child
                         (1 L/day) or an adult (2 L/day).
One-day Health Advisory

     No data were found in the available literature that were suitable for
determination of the One-day HA value.  It is, therefore, recommended that
the Ten-day HA value for a 10-kg child (2.5 mg/L, calculated below) be used
at this time as a conservative estimate of the One-day HA value.

Ten-day Health Advisory

     The rat teratology study by Beliles and Mueller  (1976) has been selected
to serve as the basis for determination of the Ten-day HA value for a 10-kg
child for chloramben.  In this study, a NOAEL of 225  mg/kg/day, the highest
dose tested, was identified for maternal toxicity and teratogenicity while a
NOAEL of 25 mg/kg/day was identified for fetotoxicity (skeletal development)
in rats exposed on days 6 to 15 of gestation.  There  is some question as to
whether it is appropriate to base a Ten-day HA for the 10-kg child on
fetotoxicity observed in a teratology study.  However, this study is of
appropriate duration and the fetus may be more sensitive than the 10-kg
child.

     The studies by Keller (1959) and Holson (1984) have not been selected,
since the NOAEL values identified in these studies (500 and 1,000 mg/kg/day,
respectively) are much higher than the NOAEL identified by Beliles and Mueller
(1976).

     Using the NOAEL of 25 mg/kg/day, the Ten-day HA  for the 10-kg child is
calculated as follows:

         Ten-day HA = (25 mg/kg/day) (10 kg) . 2<5    /L (2,5oo ug/L)
                         (100) (1 L/day)
where:
         25 mg/kg/day = NOAEL, based on the absence of systemic toxic effects
                       in rats fed chloramben for 10 days.

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Chloramben                                                   August, 1987

                                     -10-


               10 kg - assumed body weight of a child.

                 100 » uncertainty factor, chosen in accordance with NAS/ODW
                       guidelines for use with a NOAEL from an animal study.

             1 L/day * assumed daily water consumption of a child.

Longer-term Health Advisories

     No data were found in the available literature that were suitable for
the determination of the Longer-term HA.  It is, therefore, recommended that
an adjusted DWEL for a 10-kg child (0.15 mg/L - 150 ug/L) and the DWEL for
a 70-kg adult (0.525 mg/L - 525 ug/L) be used at this time for the Longer-
term HA values.

Lifetime Health Advisory

     The Lifetime HA represents that portion of an individual's total exposure
that is attributed to drinking water and is considered protective of noncar-
cinogenic adverse health effects over a lifetime exposure.  The Lifetime HA
is derived in a three step process.  Step 1 determines the Reference Dose
(RfD), formerly called the Acceptable Daily Intake (ADI).  The RfD is an esti-
mate of a daily exposure to the human population that is likely to be without
appreciable risk of deleterious effects over a lifetime, and is derived from
the NOAEL (or LOAEL), identified from a chronic (or subchronic) study, divided
by an uncertainty factor(s).  From the RfD, a Drinking Water Equivalent Level
(DWEL) can be determined (Step 2).  A DWEL is a medium-specific (i.e., drinking
water) lifetime exposure level, assuming 100% exposure from that medium, at
which adverse, noncarcinogenic health effects would not be expected to occur.
The DWEL is derived from the multiplication of the RfD by the assumed body
weight of an adult and divided by the assumed daily water consumption of an
adult.  The Lifetime HA is determined in Step 3 by factoring in other sources
of exposure, the relative source contribution (RSC).  The RSC from drinking
water is based on actual exposure data or, if data are not available, a
value of 20% is assumed for synthetic organic chemicals and a value of 10%
is assumed for inorganic chemicals.  If the contaminant is classified as a
Group A or B carcinogen, according to the Agency's classification scheme of
carcinogenic potential (U.S. EPA, 1986a), then caution should be exercised in
assessing the risks associated with lifetime exposure to this chemical.

     The 18-month feeding study by the Huntingdon Research Center (1978;
cited in U.S. EPA, 1981) has been selected to serve as the basis for determina-
tion of the Lifetime HA for Chloramben.  In this study, Crl:COBS CD-1 mice
were administered technical Chloramben at dietary levels of 0, 100, 1,000 or
10,000 ppm (0, 15, 150 or 1,500 mg/kg/day).  Hepatocellular alterations were
observed in mice  in all treatment groups, and a LOAEL of 100 ppm (15 mg/kg/day)
was identified.   Other studies of appropriate duration identify NOAELs that
are higher than the LOAEL of 15 mg/kg/day.  For example, Hazleton and Farmer
(1963) identified a NOAEL of 250 mg/kg/day in a 2-year study i-n dogs, and
both Paynter et al. (1963) and Johnston and Siebold (1979) identified a
NOAEL of 500 mg/kg/day in 2-year rat studies.

     Using the LOAEL of 15 mg/kg/day, the Lifetime HA for Chloramben is
calculated as follows:

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Chloramben                                                   August, 1987

                                     -11-


Step 1:  Determination of the Reference Dose (RfD)

                    RfD « (15 mg/kg/day) „ 0.015 mg/kg/day
                             (1,000)

where:

       15 mg/kg/day = LOAEL,  based on hepatic effects in mice exposed to
                      chloramben via  the diet for 18 months.

              1,000 = uncertainty factor, chosen in accordance with NAS/ODW
                      guidelines for  use with a LOAEL from an animal study.

Step 2:  Determination of the Drinking Water Equivalent Level (DWEL)

           DWEL = (0.015 mg/kg/day) (70 kg) = 0.525 mg/L (525 ug/L)
                          (2  L/day)

where:

        0.015 mg/kg/day = RfD.

                  70 kg = assumed body weight of an adult.

                2 L/day = assumed daily water consumption of an adult.

Step 3:  Determination of the Lifetime Health Advisory

           Lifetime HA = (0.525 mg/L) (20%) = 0.105 mg/L (105 ug/L)

where:

        0.525 mg/L = DWEL.

               20% = assumed  relative source contribution from water.

Evaluation of Carcinogenic Potential

     0   NCI (1977) evaluated  the carcinogenic potential of orally admini-
        stered chloramben (10,000 or  20,000 ppm, equivalent to 500 or 1,000
        mg/kg/day) to Osborne-Mendel  rats (50/sex/dose) and B6C3F-| mice
        (20/sex/dose) for 80  weeks.  It was concluded in a retrospective
        audit of this assay (Drill et al., 1982) that under conditions of
        this study,  chloramben is not carcinogenic.  Since exposure was for
        only 80 weeks, this experiment may not have been adequate to detect
        late-occurring tumors.   Johnston and Seibold (1979) reported no evidence
        of carcinogenic activity in Sprague-Dawley rats that received chloramben
        in the diet for 2 years at concentrations up to 500 mg/kg/day.   The
        Huntingdon Research Center (1978; cited in U.S. EPA, 1981) reported
        no evidence of carcinogenicity in Crl:COBS CD-1 mice that received
        chloramben in the diet  for 18 months at concentrations  up to
        1,500 mg/kg/day.   However, due to a number of deficiencies in this
        study, no conclusion  can be made regarding the oncogenic potential

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      Chloramben                                                    August,  1987

                                           -12-
              of  the test material.   Paynter  et  al.  (1963)  reported  no evidence of
              carcinogenicity in  albino  rats  that received  chloramben in the diet
              for 2  years at concentrations up to 500 mg/kg/day.

           0  The International Agency for Research  on Cancer has not evaluated
              the carcinogenicity of  chloramben.

           0  Applying  the criteria described in EPA's guidelines for assessment of
              carcinogenic risk (U.S.  EPA, 1986a), chloramben may be classified in
              Group  D:   not classified.   This category is  for agents with inadequate
              human  and animal evidence  of carcinogenicity.


  VI.  OTHER CRITERIA, GUIDANCE AND STANDARDS

           0  NAS has determined  an Acceptable Daily Intake  of 0.25  mg/kg/day with
              a  Suggested-No-Adverse-Effect-Level of 1.75  mg/L (U.S. EPA, 1985).

           0  The U.S.  EPA has established a  residue tolerance for chloramben in or
              on raw agricultural commodities of 0.1 ppm (CFR, 1985).


 VII.  ANALYTICAL METHODS

           p  Chloramben may be analyzed using a gas chromatographic (GC) method
              applicable to the determination of chlorinated acids,  ethers and
              esters in water samples (U.S. EPA,  1986b).  In this method, approx-
              imately 1  liter of  sample  is acidified.  The compounds are extracted
              with ethyl ether using  a separatory funnel.   The derivatives are
              hydrolyzed with potassium  hydroxide, and extraneous organic material
              is removed by a solvent wash.   After acidification, the acids are
              extracted and converted to their methyl esters using diazomethane as
              the derivatizing agent.  Excess reagent is removed, and the esters
              are determined by electron-capture (EC) gas  chromatography.  The
              method detection limit  has not  been determined for  this compound.


VIII.  TREATMENT  TECHNOLOGIES

           0  No data were found  for  the removal of  chloramben from drinking water
              by conventional treatment.

           0  No data were found  for  the removal of  chloramben from drinking water
              by activated carbon treatment.  However, due to its low solubility
              and its high molecular  weight,  chloramben probably  would be amenable
              to activated carbon adsorption.

           0  No data were found  for  the removal of  chloramben from drinking water
              by ion exchange.  However, chloramben  is an  acidic  pesticide and
              these  compounds have been  readily  adsorbed in large amounts by ion
              exchange  resins.  Therefore, chloramben probably would be amenable
              to an  ion exchange.

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Chloramben                                                   August, 1987

                                     -13-
        No data were found for the removal of chloramben from drinking water
        by aeration.  However, the Henry's Coefficient can be estimated from
        available data on solubility (700 mg/L at 25°C)  and vapor pressure
        (7 x 10~3 mm Hg at 100°C).  Due to its estimated Henry's Coeeficient
        of 0.15 a tan, chloramben probably would not be amenable to aeration or
        air stripping.

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    Chloramben                                                   August, 1987

                                         -14-


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Chloramben                                                   August,  1987

                                     -15-
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Chloramben                                                   August,  1987

                                     -16-
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  Programs.

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