An Upper‐Bound Assessment of the Benefits of Reducing Perchlorate in Drinking Water

The Environmental Protection Agency plans to issue new federal regulations to limit drinking water concentrations of perchlorate, which occurs naturally and results from the combustion of rocket fuel. This article presents an upper‐bound estimate of the potential benefits of alternative maximum contaminant levels for perchlorate in drinking water. The results suggest that the economic benefits of reducing perchlorate concentrations in drinking water are likely to be low, i.e., under $2.9 million per year nationally, for several reasons. First, the prevalence of detectable perchlorate in public drinking water systems is low. Second, the population especially sensitive to effects of perchlorate, pregnant women who are moderately iodide deficient, represents a minority of all pregnant women. Third, and perhaps most importantly, reducing exposure to perchlorate in drinking water is a relatively ineffective way of increasing iodide uptake, a crucial step linking perchlorate to health effects of concern.     

Does EPA Underestimate Cancer Risks by Ignoring Susceptibility Differences?

A 2009 report of the National Research Council (NRC) recommended that the U.S. Environmental Protection Agency (EPA) increase its estimates of increased cancer risk from exposure to environmental agents by ～7‐fold, due to an approximate ～25‐fold typical ratio between the median and upper 95th percentile persons’ cancer sensitivity assuming approximately lognormally distributed sensitivities. EPA inaction on this issue has raised concerns that cancer risks to environmentally exposed populations remain systematically underestimated. This concern is unwarranted, however, because EPA point estimates of cancer risk have always pertained to the average, not the median, person in each modeled exposure group. Nevertheless, EPA has yet to explain clearly how its risk characterization and risk management policies concerning individual risks from environmental chemical carcinogens do appropriately address broad variability in human cancer susceptibility that has been a focus of two major NRC reports to EPA concerning its risk assessment methods.     

Computer Models Used to Support Cleanup Decision-Making at Hazardous and Radioactive Waste Sites

Massive efforts are underway to clean up hazardous and radioactive waste sites located throughout the United States. To help determine cleanup priorities, computer models are being used to characterize the source, transport, fate, and effects of hazardous chemicals and radioactive materials found at these sites. Although the U.S. Environmental Protection Agency (EPA), the U.S. Department of Energy (DOE), and the U.S. Nuclear Regulatory Commission (NRC)have provided preliminary guidance to promote the use of computer models for remediation purposes, no agency has produced directed guidance on models that must be used in these efforts. As a result, model selection is currently done on an ad hoc basis. This is administratively ineffective and costly, and can also result in technically inconsistent decision-making. To identify what models are actually being used to support decision-making at hazardous and radioactive waste sites, a project jointly funded by EPA, DOE, and NRC was initiated. The purpose of this project was to: (1)identify models being used for hazardous and radioactive waste site assessment purposes; and (2)describe and classify these models. This report presents the results of this study. A mail survey was conducted to identify models in use. The survey was sent to 550 persons engaged in the cleanup of hazardous and radioactive waste sites; 87 individuals responded. They represented organizations including federal agencies, national laboratories, and contractor organizations. The respondents identified 127 computer models that were being used to help support cleanup decision-making. There were a few models that appeared to be used across a large number of sites (e.g., RESRAD). In contrast, the survey results also suggested that most sites were using models which were not reported in use elsewhere. Information is presented on the types of models being used and the characteristics of the models in use. Also shown is a list of models available, but not identified in the survey itself.     

Aldrin and Dieldrin: A Reevaluation of the Cancer and Noncancer Dose‐Response Assessments

The dose‐response analyses of cancer and noncancer health effects of aldrin and dieldrin were evaluated using current methodology, including benchmark dose analysis and the current U.S. Environmental Protection Agency (U.S. EPA) guidance on body weight scaling and uncertainty factors. A literature review was performed to determine the most appropriate adverse effect endpoints. Using current methodology and information, the estimated reference dose values were 0.0001 and 0.00008 mg/kg‐day for aldrin and dieldrin, respectively. The estimated cancer slope factors for aldrin and dieldrin were 3.4 and 7.0 (mg/kg‐day)^?1, respectively (i.e., about 5‐ and 2.3‐fold lower risk than the 1987 U.S. EPA assessments). Because aldrin and dieldrin are no longer used as pesticides in the United States, they are presumed to be a low priority for additional review by the U.S. EPA. However, because they are persistent and still detected in environmental samples, quantitative risk assessments based on the best available methods are required. Recent epidemiologic studies do not demonstrate a causal association between aldrin and dieldrin and human cancer risk. The proposed reevaluations suggest that these two compounds pose a lower human health risk than currently reported by the U.S. EPA.     

Use of Markov Chain Monte Carlo Analysis with a Physiologically-Based Pharmacokinetic Model of Methylmercury to Estimate Exposures in U.S. Women of Childbearing Age

A Bayesian approach, implemented using Markov Chain Monte Carlo (MCMC) analysis, was applied with a physiologically‐based pharmacokinetic (PBPK) model of methylmercury (MeHg) to evaluate the variability of MeHg exposure in women of childbearing age in the U.S. population. The analysis made use of the newly available National Health and Nutrition Survey (NHANES) blood and hair mercury concentration data for women of age 16–49 years (sample size, 1,582). Bayesian analysis was performed to estimate the population variability in MeHg exposure (daily ingestion rate) implied by the variation in blood and hair concentrations of mercury in the NHANES database. The measured variability in the NHANES blood and hair data represents the result of a process that includes interindividual variation in exposure to MeHg and interindividual variation in the pharmacokinetics (distribution, clearance) of MeHg. The PBPK model includes a number of pharmacokinetic parameters (e.g., tissue volumes, partition coefficients, rate constants for metabolism and elimination) that can vary from individual to individual within the subpopulation of interest. Using MCMC analysis, it was possible to combine prior distributions of the PBPK model parameters with the NHANES blood and hair data, as well as with kinetic data from controlled human exposures to MeHg, to derive posterior distributions that refine the estimates of both the population exposure distribution and the pharmacokinetic parameters. In general, based on the populations surveyed by NHANES, the results of the MCMC analysis indicate that a small fraction, less than 1%, of the U.S. population of women of childbearing age may have mercury exposures greater than the EPA RfD for MeHg of 0.1 μg/kgg/day, and that there are few, if any, exposures greater than the ATSDR MRL of 0.3 μgg/kgg/day. The analysis also indicates that typical exposures may be greater than previously estimated from food consumption surveys, but that the variability in exposure within the population of U.S. women of childbearing age may be less than previously assumed.     

Linking Indoor Air and Pharmacokinetic Models to Assess Tetrachloroethylene Risk

Physiologically based pharmacokinetic (PBPK) models describing the uptake, metabolism, and excretion of xenobiotic compounds are now proposed for use in regulatory health-risk assessments. In this study we investigate the extent of PCE metabolism arising from domestic respiratory exposure to tetrachloroethylene (PCE) from ground water, as predicted using a PBPK model. Indoor exposure patterns we use as input to the PBPK model are realistic ones generated from a three-compartment model describing volatilization of PCE from domestic water into household air. Values we use for the metabolic parameters of the PBPK model are estimated from data on urinary metabolites in workers exposed to PCE. It is shown that for respiratory PCE exposure due to typical levels of PCE in ground water, use of time-weighted average air concentrations with a steady-state PBPK model yields estimates of total metabolized PCE similar to those obtained using completely dynamic modeling, despite considerable uncertainty in key exposure- and metabolic-model parameters. These findings suggest that, for PCE, risk estimation taking pharmacokinetics into account may be accomplished using a simple analytic approach.     

Benchmark Dose Risk Assessment for Formaldehyde Using Airflow Modeling and a Single-Compartment, DNA-Protein Cross-Link Dosimetry Model to Estimate Human Equivalent Doses

Formaldehyde induced squamous-cell carcinomas in the nasal passages of F344 rats in two inhalation bioassays at exposure levels of 6 ppm and above. Increases in rates of cell proliferation were measured by T. M. Monticello and colleagues at exposure levels of 0.7 ppm and above in the same tissues from which tumors arose. A risk assessment for formaldehyde was conducted at the CIIT Centers for Health Research, in collaboration with investigators from Toxicological Excellence in Risk Assessment (TERA) and the U.S. Environmental Protection Agency (U.S. EPA) in 1999. Two methods for dose-response assessment were used: a full biologically based modeling approach and a statistically oriented analysis by benchmark dose (BMD) method. This article presents the later approach, the purpose of which is to combine BMD and pharmacokinetic modeling to estimate human cancer risks from formaldehyde exposure. BMD analysis was used to identify points of departure (exposure levels) for low-dose extrapolation in rats for both tumor and the cell proliferation endpoints. The benchmark concentrations for induced cell proliferation were lower than for tumors. These concentrations were extrapolated to humans using two mechanistic models. One model used computational fluid dynamics (CFD) alone to determine rates of delivery of inhaled formaldehyde to the nasal lining. The second model combined the CFD method with a pharmacokinetic model to predict tissue dose with formaldehyde-induced DNA-protein cross-links (DPX) as a dose metric. Both extrapolation methods gave similar results, and the predicted cancer risk in humans at low exposure levels was found to be similar to that from a risk assessment conducted by the U.S. EPA in 1991. Use of the mechanistically based extrapolation models lends greater certainty to these risk estimates than previous approaches and also identifies the uncertainty in the measured dose-response relationship for cell proliferation at low exposure levels, the dose-response relationship for DPX in monkeys, and the choice between linear and nonlinear methods of extrapolation as key remaining sources of uncertainty.     

Enhancing the Characterization of Epistemic Uncertainties in PM2.5 Risk Analyses

The Environmental Benefits Mapping and Analysis Program (BenMAP) is a software tool developed by the U.S. Environmental Protection Agency (EPA) that is widely used inside and outside of EPA to produce quantitative estimates of public health risks from fine particulate matter (PM_2.5). This article discusses the purpose and appropriate role of a risk analysis tool to support risk management deliberations, and evaluates the functions of BenMAP in this context. It highlights the importance in quantitative risk analyses of characterization of epistemic uncertainty, or outright lack of knowledge, about the true risk relationships being quantified. This article describes and quantitatively illustrates sensitivities of PM_2.5 risk estimates to several key forms of epistemic uncertainty that pervade those calculations: the risk coefficient, shape of the risk function, and the relative toxicity of individual PM_2.5 constituents. It also summarizes findings from a review of U.S.‐based epidemiological evidence regarding the PM_2.5 risk coefficient for mortality from long‐term exposure. That review shows that the set of risk coefficients embedded in BenMAP substantially understates the range in the literature. We conclude that BenMAP would more usefully fulfill its role as a risk analysis support tool if its functions were extended to better enable and prompt its users to characterize the epistemic uncertainties in their risk calculations. This requires expanded automatic sensitivity analysis functions and more recognition of the full range of uncertainty in risk coefficients.     

Part II: Quantitative Evaluation of Choices Used in Setting Noncancer Chronic Human Health Reference Values Across Organizations

Environmental and public health organizations, including the World Health Organization (WHO) and the U.S. Environmental Protection Agency (USEPA), develop human health reference values (HHRV) that set “safe” levels of exposure to noncarcinogens. Here, we systematically analyze chronic HHRVs from four organizations: USEPA, Health Canada, RIVM (the Netherlands), and the U.S. Agency for Toxic Substances and Disease Registry. This study is an extension of our earlier work and both closely examines the choices made in setting HHRVs and presents a quantitative method for identifying the primary factors influencing HHRV agreement or disagreement.⁽¹⁾ We evaluated 171 organizational comparisons, developing a quantitative method for identifying the factors to which HHRV agreement (that is, when both organizations considering the same data set the identical HHRV values) is most sensitive. To conduct this analysis, a Bayesian belief network was built using expert judgment, including the specific science policy choices analysis made in the context of setting an HHRV. Based on a sensitivity of findings analysis, HHRV agreement is most sensitive to the point of departure value, followed by the total uncertainty factor (UF), critical study, critical effect, animal model, and point of departure approach. This analysis also considered the specific impacts of individual UFs, with the database UF and the subchronic‐to‐chronic UF being identified as primary factors impacting the total UF differences observed across organizations. The sensitivity of findings analysis results were strengthened and confirmed by frequency analyses evaluating which choices most often disagreed when the HHRV and the total UF disagreed.     

Combining Occurrence and Toxicity Information to Identify Priorities for Drinking-Water Mixture Research

Characterizing all possible chemical mixtures in drinking water is a potentially overwhelming project, and the task of assessing each mixture's net toxicity even more daunting. We propose that analyzing occurrence information on mixtures in drinking water may help to narrow the priorities and inform the approaches taken by researchers in mixture toxicology. To illustrate the utility of environmental data for refining the mixtures problem, we use a recent compilation of national ground-water-quality data to examine proposed U.S. Environmental Protection Agency (EPA) and Agency for Toxic Substances and Disease Registry (ATSDR) models of noncancer mixture toxicity. We use data on the occurrence of binary and ternary mixtures of arsenic, cadmium, and manganese to parameterize an additive model and compute hazard index scores for each drinking-water source in the data set. We also use partially parameterized interaction models to perform a bounding analysis estimating the interaction potential of several binary and ternary mixtures for which the toxicological literature is limited. From these results, we estimate a relative value of additional toxicological information for each mixture. For example, we find that according to the U.S. EPA's interaction model, the levels of arsenic and cadmium found in U.S. drinking water are unlikely to have synergistic cardiovascular effects, but the same mixture's potential for synergistic neurological effects merits further study. Similar analysis could in future be used to prioritize toxicological studies based on their potential to reduce scientific and regulatory uncertainty. Environmental data may also provide a means to explore the implications of alternative risk models for the toxicity and interaction of complex mixtures.     

A Risk Assessment for Selected Lead-Induced Health Effects: An Example of a General Methodology

The research described here is part of a larger risk assessment project to aid the U.S. Environmental Protection Agency (EPA) in its review of the primary National Ambient Air Quality Standard for lead. The methodology can be applied to many situations in which a policy decision about a toxic substance is required in the face of incomplete data. Numerical results are presented for three potentially adverse lead-induced effects of interest to EPA: elevated erythrocyte protoporphyrin (EP), hemoglobin (Hb) decrement, and intelligence quotient (IQ) decrement.     

Resolution of the Long-Term Performance Issues at the Waste Isolation Pilot Plant

The Waste Isolation Pilot Plant (WIPP) is a geological repository for disposal of U.S. defense transuranic radioactive waste. Built and operated by the U.S. Department of Energy (DOE), it is located in the Permian age salt beds in southeastern New Mexico at a depth of 655 m. Performance assessment for the repository's compliance with the 10,000-year containment standards was completed in 1996 and the U.S. Environmental Protection Agency (EPA) certified in 1998 that the repository meets compliance with the EPA standards 40 CFR 191 and 40 CFR 194. The Environmental Evaluation Group (EEG) review of the DOE's application for certification identified a number of issues. These related to the scenarios, conceptual models, and values of the input parameters used in the calculations. It is expected that these issues will be addressed and resolved during the first 5-year recertification process that began with the first receipt of waste at WIPP on March 26, 1999, and scheduled to be completed in March 2004.     

A Trichloroethylene Risk Assessment Using a Monte Carlo Analysis of Parameter Uncertainty in Conjunction with Physiologically-Based Pharmacokinetic Modeling

A Monte Carlo simulation is incorporated into a risk assessment for trichloroethylene (TCE) using physiologically-based pharmacokinetic (PBPK) modeling coupled with the linearized multistage model to derive human carcinogenic risk extrapolations. The Monte Carlo technique incorporates physiological parameter variability to produce a statistically derived range of risk estimates which quantifies specific uncertainties associated with PBPK risk assessment approaches. Both inhalation and ingestion exposure routes are addressed. Simulated exposure scenarios were consistent with those used by the Environmental Protection Agency (EPA) in their TCE risk assessment. Mean values of physiological parameters were gathered from the literature for both mice (carcinogenic bioassay subjects) and for humans. Realistic physiological value distributions were assumed using existing data on variability. Mouse cancer bioassay data were correlated to total TCE metabolized and area-under-the-curve (blood concentration) trichloroacetic acid (TCA) as determined by a mouse PBPK model. These internal dose metrics were used in a linearized multistage model analysis to determine dose metric values corresponding to 10^-6 lifetime excess cancer risk. Using a human PBPK model, these metabolized doses were then extrapolated to equivalent human exposures (inhalation and ingestion). The Monte Carlo iterations with varying mouse and human physiological parameters produced a range of human exposure concentrations producing a 10^-6 risk.     

On Intergenerational Equity and Its Clash with Intragenerational Equity and on the Need for Policies to Guide the Regulation of Disposal of Wastes and Other Activities Posing Very Long-Term Risks

This article begins with some history of the derivation of 40 CFR Part 191, the U.S. Environmental Protection Agency (EPA) standard that governs the geologic disposal of spent nuclear fuel and high-level and transuranic radioactive wastes. This is followed by criticisms of the standard that were made by a Sub-Committee of the EPA Science Advisory Board, by the staff of the U.S. Nuclear Regulatory Commission, and by a panel of the National Academies of Science and Engineering. The large disparity in the EPA approaches to regulation of disposal of radioactive wastes and disposal of hazardous, long-lived, nonradioactive chemical waste is illustrated. An examination of the intertwined matters of intergenerational equity and the discounting of future health effects follows, together with a discussion of the conflict between intergenerational equity and intragenerational equity. Finally, issues related to assumptions in the regulations concerning the future state of society and the biosphere are treated, as is the absence of any national philosophy or guiding policy for how to deal with societal activities that pose very long-term risks.     

Development of a Screening Approach to Interpret Human Biomonitoring Data on Volatile Organic Compounds: Reverse Dosimetry on Biomonitoring Data for Trichloroethylene

A screening approach is developed for volatile organic compounds (VOCs) to estimate exposures that correspond to levels measured in fluids and/or tissues in human biomonitoring studies. The approach makes use of a generic physiologically-based pharmacokinetic (PBPK) model coupled with exposure pattern characterization, Monte Carlo analysis, and quantitative structure property relationships (QSPRs). QSPRs are used for VOCs with minimal data to develop chemical-specific parameters needed for the PBPK model. The PBPK model is capable of simulating VOC kinetics following multiple routes of exposure, such as oral exposure via water ingestion and inhalation exposure during shower events. Using published human biomonitoring data of trichloroethylene (TCE), the generic model is evaluated to determine how well it estimates TCE concentrations in blood based on the known drinking water concentrations. In addition, Monte Carlo analysis is conducted to characterize the impact of the following factors: (1) uncertainties in the QSPR-estimated chemical-specific parameters; (2) variability in physiological parameters; and (3) variability in exposure patterns. The results indicate that uncertainty in chemical-specific parameters makes only a minor contribution to the overall variability and uncertainty in the predicted TCE concentrations in blood. The model is used in a reverse dosimetry approach to derive estimates of TCE concentrations in drinking water based on given measurements of TCE in blood, for comparison to the U.S. EPA's Maximum Contaminant Level in drinking water. This example demonstrates how a reverse dosimetry approach can be used to facilitate interpretation of human biomonitoring data in a health risk context by deriving external exposures that are consistent with a biomonitoring data set, thereby permitting comparison with health-based exposure guidelines.     

Improving Cancer Dose–Response Characterization by Using Physiologically Based Pharmacokinetic Modeling: An Analysis of Pooled Data for Acrylonitrile-Induced Brain Tumors to Assess Cancer Potency in the Rat

Historically, U.S. regulators have derived cancer slope factors by using applied dose and tumor response data from a single key bioassay or by averaging the cancer slope factors of several key bioassays. Recent changes in U.S. Environmental Protection Agency (EPA) guidelines for cancer risk assessment have acknowledged the value of better use of mechanistic data and better dose–response characterization. However, agency guidelines may benefit from additional considerations presented in this paper. An exploratory study was conducted by using rat brain tumor data for acrylonitrile (AN) to investigate the use of physiologically based pharmacokinetic (PBPK) modeling along with pooling of dose–response data across routes of exposure as a means for improving carcinogen risk assessment methods. In this study, two contrasting assessments were conducted for AN-induced brain tumors in the rat on the basis of (1) the EPA's approach, the dose–response relationship was characterized by using administered dose/concentration for each of the key studies assessed individually; and (2) an analysis of the pooled data, the dose–response relationship was characterized by using PBPK-derived internal dose measures for a combined database of ten bioassays. The cancer potencies predicted for AN by the contrasting assessments are remarkably different (i.e., risk-specific doses differ by as much as two to four orders of magnitude), with the pooled data assessments yielding lower values. This result suggests that current carcinogen risk assessment practices overestimate AN cancer potency. This methodology should be equally applicable to other data-rich chemicals in identifying (1) a useful dose measure, (2) an appropriate dose–response model, (3) an acceptable point of departure, and (4) an appropriate method of extrapolation from the range of observation to the range of prediction when a chemical's mode of action remains uncertain.     

Structure and Parameterization of Pharmacokinetic Models: Their Impact on Model Predictions

There has been an increasing interest in physiologically based pharmacokinetic (PBPK)models in the area of risk assessment. The use of these models raises two important issues: (1)How good are PBPK models for predicting experimental kinetic data? (2)How is the variability in the model output affected by the number of parameters and the structure of the model? To examine these issues, we compared a five-compartment PBPK model, a three-compartment PBPK model, and nonphysiological compartmental models of benzene pharmacokinetics. Monte Carlo simulations were used to take into account the variability of the parameters. The models were fitted to three sets of experimental data and a hypothetical experiment was simulated with each model to provide a uniform basis for comparison. Two main results are presented: (1)the difference is larger between the predictions of the same model fitted to different data se1ts than between the predictions of different models fitted to the dame data; and (2)the type of data used to fit the model has a larger effect on the variability of the predictions than the type of model and the number of parameters.     

Improving cancer dose-response characterization by using physiologically based pharmacokinetic modeling: an analysis of pooled data for acrylonitrile-induced brain tumors to assess cancer potency in the rat.

Historically, U.S. regulators have derived cancer slope factors by using applied dose and tumor response data from a single key bioassay or by averaging the cancer slope factors of several key bioassays. Recent changes in U.S. Environmental Protection Agency (EPA) guidelines for cancer risk assessment have acknowledged the value of better use of mechanistic data and better dose-response characterization. However, agency guidelines may benefit from additional considerations presented in this paper. An exploratory study was conducted by using rat brain tumor data for acrylonitrile (AN) to investigate the use of physiologically based pharmacokinetic (PBPK) modeling along with pooling of dose-response data across routes of exposure as a means for improving carcinogen risk assessment methods. In this study, two contrasting assessments were conducted for AN-induced brain tumors in the rat on the basis of (1) the EPA's approach, the dose-response relationship was characterized by using administered dose/concentration for each of the key studies assessed individually; and (2) an analysis of the pooled data, the dose-response relationship was characterized by using PBPK-derived internal dose measures for a combined database of ten bioassays. The cancer potencies predicted for AN by the contrasting assessments are remarkably different (i.e., risk-specific doses differ by as much as two to four orders of magnitude), with the pooled data assessments yielding lower values. This result suggests that current carcinogen risk assessment practices overestimate AN cancer potency. This methodology should be equally applicable to other data-rich chemicals in identifying (1) a useful dose measure, (2) an appropriate dose-response model, (3) an acceptable point of departure, and (4) an appropriate method of extrapolation from the range of observation to the range of prediction when a chemical's mode of action remains uncertain.     

Evaluating the Risk of Liver Cancer in Humans Exposed to Trichloroethylene Using Physiological Models

Trichloroethylene (TCE) is a widespread environmental pollutant. TCE is classified as a rodent carcinogen by the U.S. Environmental Protection Agency (EPA). Using the rodent cancer bioassay findings and estimates of metabolized dose, the EPA has estimated lifetime exposure cancer risks for humans that ingest TCE in drinking water or inhale TCE. In this study, a physiologically based pharmacokinetic (PB-PK) model for mice was used to simulate selected gavage and inhalation bioassays with TCE. Plausible dose-metrics thought to be linked with the mechanism of action for TCE carcinogenesis were selected. These dose-metrics, adjusted to reflect an average amount per day for a lifetime, were metabolism of TCE (AMET, mg/kg/day) and systemic concentration of TCA (AUCTCA, mg/L/day). These dose-metrics were then used in a linearized multistage model to estimate AMET and AUCTCA values that correspond to liver cancer risks of 1 in 1 million in mice. A human PB-PK model for TCE was then used to predict TCE concentrations in drinking water and air that would provide AMET and AUCTCA values equal to the predicted mice AMET and AUCTCA values that correspond to liver cancer risks of 1 in 1 million. For the dose-metrics, AMET and AUCTCA, the TCE concentrations in air were 10.0 and 0.1 ppb TCE (continuous exposure), respectively, and in water, 7 and 4 μg TCE/L, respectively.     

Evaluation of the Uncertainty in an Oral Reference Dose for Methylmercury Due to Interindividual Variability in Pharmacokinetics

An analysis of the uncertainty in guidelines for the ingestion of methylmercury (MeHg) due to human pharmacokinetic variability was conducted using a physiologically based pharmacokinetic (PBPK) model that describes MeHg kinetics in the pregnant human and fetus. Two alternative derivations of an ingestion guideline for MeHg were considered: the U.S. Environmental Protection Agency reference dose (RfD) of 0.1 g/kg/day derived from studies of an Iraqi grain poisoning episode, and the Agency for Toxic Substances and Disease Registry chronic oral minimal risk level (MRL) of 0.5 g/kg/day based on studies of a fish-eating population in the Seychelles Islands. Calculation of an ingestion guideline for MeHg from either of these epidemiological studies requires calculation of a dose conversion factor (DCF) relating a hair mercury concentration to a chronic MeHg ingestion rate. To evaluate the uncertainty in this DCF across the population of U.S. women of child-bearing age, Monte Carlo analyses were performed in which distributions for each of the parameters in the PBPK model were randomly sampled 1000 times. The 1st and 5th percentiles of the resulting distribution of DCFs were a factor of 1.8 and 1.5 below the median, respectively. This estimate of variability is consistent with, but somewhat less than, previous analyses performed with empirical, one-compartment pharmacokinetic models. The use of a consistent factor in both guidelines of 1.5 for pharmacokinetic variability in the DCF, and keeping all other aspects of the derivations unchanged, would result in an RfD of 0.2 g/kg/day and an MRL of 0.3 g/kg/day.