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Food Safety and Toxicology

CD Carrington, College Park, MD, USA


PM Bolger, Annapolis, MD, USA
Ó 2014 Elsevier Inc. All rights reserved.

Background to diminish as the sensitivity of the measurement or the


number of observations increases. Since the burden of proof is
The Federal Food Safety Program resides in part under the on science to show that an effect has occurred, greater
authority of the US Food and Drug Administration. The specific uncertainty tends to raise the level of exposure that is deemed
statutory authority is the Federal Food, Drug, and Cosmetic Act acceptable/tolerable. The selection of the effect that is
(FFDCA). The areas of responsibility include the consideration considered adverse is a matter of societal values (i.e., local-
of the safety or risk of food and color additives, both direct ized, reversible, mild discomfort versus frank, and irreversible
and indirect, and food-borne contaminants, both natural and systemic toxicity). That is, establishing that an effect has
anthropogenic. The FFDCA prescribes somewhat different occurred is a separate consideration from how much one cares
standards of safety/risk for intentional food additives that if it will occur or not.
undergo premarket assessment of safety, specifically, versus In the original safety assessment paradigm, a single SF of
those dietary constituents that are found in food as contami- 100 was used to derive an ADI from an NOEL. The justification
nants because they occur naturally or because they arise from of the SF (also called a UF) was based on scientific consider-
anthropogenic sources. ations as well as a judgment about how to manage the inherent
The prototypical safety assessment for food-borne uncertainty associated with the assessment. Scientific issues
compounds is the acceptable daily intake (ADI) methodology, raised included the notion that humans may be more sensitive
which was first documented in 1954, and has come to be to chemicals than rodents used in a laboratory test and that
employed throughout the world. This paradigm has also been there may be substantial variability among individuals in
codified in the consideration of food (e.g., aspartame) and a population. The necessity of managing uncertainty was
color additives (e.g., Red Dye No. 2) and pesticides (e.g., acknowledged through the recognition that it is impossible to
atrazine). It is also routinely used in the consideration of demonstrate that no adverse affect could not occur under any
incidental food-borne chemical contaminants (e.g., lead), circumstances. As the ADI approach evolved, the single SF was
particularly as a tool for screening out trivial incidents of replaced by two or more SF/UFs of 10, with each factor applied
exposure. This procedure specifies that an acceptable dose of as a response to a particular scientific issue. For example, an
a chemical may be calculated with the following equation: NOEL/NOAEL from an animal experiment is normally divided
by a factor of 10 as a matter of policy in response to the
ADI ¼ NOEL=SF
supposition that humans may be more sensitive than labora-
where ADI is the acceptable daily intake, NOEL is the no- tory animals and by another factor of 10 to account for vari-
observed-effect level, and SF is a safety factor. In subsequent ability of response in the population of concern. SF/UFs dictate
considerations, an identical methodology has been imple- the impact of uncertainty of some quantity on the decision.
mented where new terms have been substituted for those Although the magnitude of the uncertainty is not precisely
originally described for the ADI safety assessment method- described, the general idea is that the greater the uncertainty,
ology. These terms are the reference dose (RfD), minimal risk the larger the SF/UF needs to be. Thus, uncertainty in SF/UFs
level (MRL), and tolerable daily intake (TDI) for the ADI. In and uncertainty in the derivation of the NOAEL push in
these methodologies, NOEL has been further defined to be the opposite directions. As a matter of practice, the uncertainty
no-observed-adverse-effect level (NOAEL) and the SF is called underlying an SF/UF application is not quantified, so that
an uncertainty factor (UF). These alternative terms have sup- a factor of 10 is almost always employed. Even if the uncer-
planted the ADI in considerations of food-borne contaminants tainty were quantified, the magnitude of the UF would still
because unlike food additives, ‘acceptance’ is not an applicable depend on some judgment about what degree of risk adversity
term for chemical contaminants that do not have a premarket is appropriate.
approval evaluation, and therefore, these alternative terms were One outcome of the dependence of the NOEL/NOAEL on
devised. Since contaminants are not deliberately added, and for the statistical significance test is that it tends to penalize
some are fairly widespread in the environment and the food chemicals for which there is more or better data. To remedy this
chain, it is often much more difficult to achieve population problem, the benchmark dose (BMD) concept was introduced
exposures that are below an RfD/MRL/TDI. as an alternative approach. The BMD depends on the specifi-
As a general rule, the NOEL/NOAEL is a dose from cation of a low-level effect that would typically be unobserv-
a controlled animal experiment where no adverse effect able. The end point may be the specified percentage (5 or 10%)
(i.e., an effect not considered harmful) is noted. The experi- above background of a population for an end point deemed to
ment does not establish that no effect can possibly occur at be adverse. Since the end point is defined, determinations for
that dose under any conditions – it only denotes that none of different chemicals and different data sets tend to be more
the effects looked for in the experiment was observed. Since comparable.
a statistical significance test is typically used to establish Other efforts have endeavored to give SF/UFs a scientific
whether or not an effect occurred, the NOEL/NOAEL will tend basis by assembling a range of observations that are analogous

Encyclopedia of Toxicology, Volume 2 http://dx.doi.org/10.1016/B978-0-12-386454-3.00022-1 639


640 Food Safety and Toxicology

to the occasions for SF/UF application. As indicated previously, Food Risk management
while the RfD/MRL/TDI methodology is essentially the same as safety/ Prediction
Risk
for the ADI derivation, the end point has been recast as question ? Risk assessment
a threshold estimate. However, the ADI/MRL/RfD/TDI inter- Model ? Data
pretation of the product of an NOAEL as a threshold presents Research
some difficulties. First, since the number generated is partly
a product of the management of the uncertainty, it does not Figure 1 A dietary public health decision paradigm.
make sense to say that threshold of safety itself is uncertain.
Second, there is always some uncertainty about whether or not
there is a threshold, especially when considering subpopula-
tions of individuals who may already be ill. Perhaps more As with food additives, the safety assessment process for
importantly, even if the NOAEL/UF procedure is considered as contaminants is helpful in identifying chemicals that pose
a rough estimate of a threshold dose, it only provides infor- a trivial risk. However, the safety assessment process may not
mation about what may happen at that particular dose; there is be useful for those contaminants where the level of exposure in
no indication about the likelihood or frequency of an adverse a population already exceeds what has been identified as the
effect at higher doses. threshold of safety. The level specified by the safety assessment
An important part of the safety assessment process lies in process may be unattainable in all circumstances, and control
establishing the impact of scientific uncertainties on the may best be directed at reducing exposure in general rather
eventual decision. This is typically done by making conser- than attaining a particular level. Considering the best options
vative estimates that deliberately err on the side of safety. available may require better information than the safety
Since scientists are more familiar with the scientific issues, the assessment process can deliver. In this case, a formal risk
responsibility for this is often delegated to them. There are assessment is required, where the goal is to provide an estimate
two potential difficulties with this. The first problem is that of the probability of harm for a public health threat. A key
the technical person is entrusted with a decision that is partly difference between safety and quantitative risk assessment
a social/political one. This is particularly true if there is an (QRA) is that while the former is a decision process in and of
interaction between degree of uncertainty and degree of harm. itself, a QRA is intended to provide information as part of
For example, a larger degree of uncertainty may be tolerated a larger decision process – this view of risk assessment is
when the adverse effect is relatively trivial than when it illustrated in Figure 1.
is severe. However, if the technical person is not aware of all Since QRA is an applied analysis, the goal is to describe
the competing dietary and nondietary risks that impinge on what is known in response to a particular question. Where
the decision, then they may not be in a position to judge the matters of degree of exposure and risk are involved, numbers
relative importance of a particular risk. The second problem is provide more precise descriptions than words, particularly for
that a technical person may dictate the impact of the uncer- exposures that exceed the threshold of safety. In QRA, numbers
tainty for only part of the problem, without being aware of the may be used to describe both empirical quantities and, for the
other uncertainties involved. There is therefore no way to purpose of describing uncertainty, degrees of knowledge. As
judge the ‘appropriate’ degree of conservativeness for the these are two fundamentally different purposes, the benefits of
particular problem. Because the safety assessment process using quantitative tools are somewhat different. For describing
may have many steps, the decision process may be fragmented empirical quantities (e.g., body weight and heart rate),
to a degree that no one can judge whether or not a decision is numbers are useful because they are more accurate in that they
reasonable. provide a more precise statement of what is known. On the
From an administrative standpoint, a great benefit of the other hand, when describing uncertainties, the primary
safety assessment process is its relative simplicity. It deals with advantage of quantitative methods is that they are more
a broad spectrum of dietary public health issues that may be transparent, thereby allowing more people to participate in the
quite complex both socially and scientifically with a few short decision process.
rules. For small problems, the benefit of either more carefully QRA models constructed for dietary risks typically have
considering the scientific issues or encouraging widespread two main components: an exposure assessment and a dose–
participation in the decision process may not justify the effort response assessment. The exposure assessment determines the
that must be expended to do so. The efforts to improve amount of a chemical contaminant that consumers will be
the scientific basis of safety assessment often result in the exposed to from the diet, and sometimes may include expo-
complexity that may result from a risk assessment without the sure from other sources as well. The dose–response assess-
benefit of clarity of purpose. There are occasions where ment characterizes the causal relationship between dietary
the safety assessment process may prove to be too simple. exposure and one or more adverse health outcomes. The
The bigger the problem is economically and politically, the interactions with risk management occur at the beginning
less comfortable the general public may be with delegating (formulating the question) and end (making the decision) of
important social/political decisions to scientists. As a result, the risk assessment process (Figure 1). In particular, risk
the safety assessment process is more useful for identifying managers often have an interest in identifying the toxic effect
small problems, than it is in dealing with large problems. For that a QRA model is designed to address. The end result is the
food additives, the safety assessment process ensures that any risk assessment model that explicitly states how a particular
risk from a compound that is intentionally added to food is adverse effect is causally related to a particular dietary expo-
trivial. sure to a contaminant.
Food Safety and Toxicology 641

Uncertainty
One hit Weibull Probit
Public health risk assessments used in considerations of food Multistage Logit Data
safety are intended to make predictions, particularly quan- 0

Log population frequency


titative, of plausible negative impacts. Obviously depending −1
on the underlying scientific information, some predictions
are more reliable than others, and the extent to which −2
predictions are reliable should be taken into account in the −3
public health decision process. Since risks of chemical −4
contaminants in food are generally small and are often
difficult to observe and measure, the uncertainties associated −5
with estimating the occurrence of potential adverse effects −6
can be large relative to the estimated effects. Therefore,
−7
consideration of uncertainty is very often an inherent part of
−6 −5 −4 −3 −2 −1 0 1
the risk assessment process.
In discussing uncertainty, it is important to distinguish Log dose (mg kg−1)
efforts to quantify uncertainty from the somewhat related
activity of characterizing the nature and extent of frequencies in Figure 2 Model uncertainty in cancer risk assessment.
a population or series. Although uncertainties may often be
reasonably calculated or based on frequencies (i.e., statistical
uncertainty), frequencies may be of interest on their own Dose–Response Models
(e.g., population variability), while some uncertainties are not
frequency based (e.g., model uncertainty). The difference Dose–response models describe a cause–effect relationship.
between probability and frequency is often a matter of context. There are a wide range of mathematical models that have been
The same distribution might be used to describe the frequency used for this purpose. The complexity of a dose–response
of an event when the question is about a population or serve as model can range from a simple one-parameter equation
the basis for a quantitative probability statement when the to complex multicompartment toxicokinetic/toxicodynamic
question is about an individual. Consider two examples. First, models. Many dose–response models, including most cancer
a distribution describing the variability of a scientific instru- risk assessment models, are population models that predict the
ment over time may be used to describe the uncertainty of frequency of a disease in a population. Such dose–response
individual measurement made by the instrument. Second, models typically employ one or more frequency distributions
a distribution describing body weight could be used to predict as part of the equation. Dose–response may also operate at an
the frequency of values expected in a population or the individual level and predict the severity of a health outcome as
uncertainty of the value in a particular individual for whom a function of dose. Particularly, complex dose–response
a measurement is unavailable. models may model both severity of outcome and population
When mathematical models are used to draw inferences, variability and perhaps even recognize the influence of
the values of the model parameters may reflect uncertainties multiple causal factors.
arising from other sources. In particular, traditional statistical Since the estimation of an adverse effect at doses consistent
methods often place confidence intervals on parameter with exposures normally seen in human populations generally
estimates that reflect the potential influence of sampling involves high to low extrapolation, uncertainty will arise from
error (i.e., the data may not be representative of the pop- the fact that different plausible models may result in very
ulation or series that an estimate is needed for). Bootstrap different estimates (see Figure 2). Model uncertainties may be
methods can be used to include other sources of uncertainty represented by constructs that are commonly referred to as
in model parameter estimates, which involve repeating the probability trees. The basic idea behind a probability tree is that
modeling process many times using different assumptions the sum of the probabilities of all the models under consid-
about either the data or the mathematical form of the eration is one. Selecting and assigning probabilities to the
models or both. nodes of a probability tree are accomplished by an evaluation
Model uncertainty arises from the availability of alterna- of the weight-of-the-evidence. To some extent, this generally
tive mathematical expressions with which an inference or involves some reliance on expert opinion. If a more formal
prediction might be made. As a practical matter, model process is necessary or desired – possibly to enable the evalu-
uncertainty is often not an important issue. In particular, so ation to be carried out by a computer – an algorithm may be
long as there are a number of observations to guide the used. Since presumably the same considerations are involved,
model that come from similar circumstances as the problem the same criteria that are used to select a ‘best’ model may also
that the analysis is concerned with, then any plausible model be used to weight them.
should yield very similar results. However, when models are
used to extrapolate values, model uncertainty can be an
important source of uncertainty. Prime examples are the use Statistics and Public Health
of models to predict outcomes at low doses (see Figure 2)
and the use of distributions to estimate the frequency of Food safety of chemical contaminants is a public health
occurrence of rare events. problem where the goal is to evaluate the toxicological
642 Food Safety and Toxicology

impact in a population rather than an individual. This adds Table 1 A methylmercury risk mitigation scenario via the use of a fish
a statistical dimension to the assessment. Population vari- advisory. Estimated IQ increases, relative to baseline, in a population after
ability is especially important for exposure assessment to a proposed fish consumption advisory
chemical contaminant since the amount of a particular food
Percentile IQ point change
consumed and the amount of chemical contaminant in
a food will vary, sometimes to a fairly extensive degree. Average 0.023 (0.009, 0.041)
Variability in dose–response relationships may also be 25th 0.000 (0.000, 0.002)
important in some cases. Median 0.007 (0.003, 0.014)
Frequency distributions may be used to represent or draw 75th 0.025 (0.009, 0.043)
inferences about the variation in a particular value among 95th 0.057 (0.023, 0.100)
a population or series (i.e., a single set of values such as body 99th 0.091 (0.036, 0.167)
99.5th 0.218 (0.086, 0.401)
weight). There are a number of ways of fitting or estimating
99.9th 0.294 (0.116, 0.573)
the parameters for a frequency distribution. The popularity of
the normal distribution may be at least partly attributed to the
fact that estimates for the parameters (with a particular set of
assumptions about the relationship between the model and the will be used in making a decision. It is important to inform the
data) can be calculated directly. There are a large number of decision maker on the summary process so that they under-
frequency models to choose from. Although there is some stand that a distribution lies behind the single number. The
theoretical basis for many of them, the theory is at best only simplest way to do this is to simply display a list of percentiles
loosely applicable to describing variability in biological pop- along with the summary statistics. The results of a 2D simula-
ulations – the biology is almost certainly more complicated than tion will necessarily be more complicated.
the model. It is often a good idea to use several models. Simulations may also be constructed to estimate the impact
It is also often possible to use empirical distributions to of potential risk mitigation procedures. If simulations are being
represent variation in exposure. In particular, simulations are run for a number of different scenarios (e.g., expected values
often constructed with food consumption surveys as the start- with and without public health intervention), it is preferable to
ing point. The simulation model can then add other sources of generate a table of summary statistics as percentiles such as
variation to produce a risk estimate for a larger population. shown in Table 1. At each percentile, an IQ change is given
Empirical distributions may also be used for other components along with the corresponding confidence limits.
of an exposure assessment (e.g., the occurrence of a chemical Although they may allow for quick comparisons, tables
contaminant in a food). On the other hand, since dose– inherently compare one value at a time. Graphing or visuali-
response relationships are always theoretical (i.e., they are not zation can be a better way of presenting the entire distribution.
directly observed), variability in population susceptibility must A 1D simulation will produce a frequency (when simulating
be modeled as well. variability) distribution or a likelihood distribution (when
representing uncertainty). There are two ways of plotting
frequency or likelihood curves: the first is to plot density versus
Risk Characterization and Simulations value (Figure 3), which emphasizes the values which are the
most common or likely, and the second is to plot cumulative
Once the overall risk assessment model is constructed, it may percentiles versus value (Figure 4), which allows the percentile
be used to make predictions. Running a large risk assessment corresponding to a particular value to be read from the plot.
model that includes exposure and a dose–response function Either plot can be used to represent either a frequency distri-
collecting the results is often referred to as a simulation. If there bution or an uncertainty that has a statistical origin.
are statistical components to the model, the model may be run
repeatedly using different random numbers to select values
from the statistical distributions each time. This process is 0.025
known as Monte Carlo simulation. In public health models,
distributions can be used to describe variability in populations
0.02
or the uncertainty in a value, parameter, or model. Since
Probability density

uncertainty is ever present, the presence of distributions in the


model that are intended to describe variability usually results in 0.015
a two-dimensional (2D) distributional model, where one
dimension represents population variability and another 0.01
represents uncertainty in the outcome.
Whether it is 1D or 2D, Monte Carlo simulation produces
many individual estimates – one per iteration. While these 0.005
numbers are the end result of the risk assessment, no one can
look at all these numbers and make sense of them. Therefore, 0
they need to be sorted and tabulated and summarized. 0 20 40 60 80 100
However, deciding how to do this involves considering how Distribution value
the results are going to be used and by whom. For example,
reporting a distribution as a mean entails that the mean is what Figure 3 A probability density curve.
Food Safety and Toxicology 643

100% 100
90%
80%
Cumulative frequency

70%

Percent
60%
50%
40%
30%
20% 0
0.50 1.50
10% Mercury blood to diet ratio
0%
0 20 40 60 80 100 Figure 6 Variability in mercury blood to diet ratios.
Distribution value

Figure 4 A cumulative frequency curve. Research proposals are justified on the basis of an expectation
that they will reduce uncertainty. There are three general
purposes that additional research may be designed to address:
1. Measurement of values used directly in risk assessment (e.g.,
90 in empirical distribution functions).
2. Collection of data that will allow more accurate estimates of
80 model parameters.
3. Collection of data that will allow discrimination among
70
models or influence weight-of-the-evidence evaluations.
60
Distribution value

50 Summary
40
Although contaminants are not intentionally added, the
30 assessment of contaminants typically begins with the applica-
Cumulative likelihood

0.99 tion of the same safety assessment process that is used for the
0.9 20
evaluation of food additives. In most instances, such an
0.5 10 assessment is sufficient in providing the assurance of safety of
0.1 the potential exposure to many dietary contaminants. There
0
0.01 0.99 are, however, other instances where the environmental
0.01 0.05 0.1 0.25 0.5 0.75 0.9 0.95
Cumulative frequency contaminant is so ubiquitous, and therefore difficult to avoid,
that a more informative analysis needs to be considered. The
Figure 5 Three-dimensional representation of risk: severity (distribution output of such an assessment is intended to describe the degree
value), frequency, and uncertainty (cumulative likelihood). of harm expected in the population and the degree of uncer-
tainty associated with the estimates. Specific areas of uncer-
tainty can also be identified that will inform and suggest
Two-dimensional results are more difficult to display. Two meaningful areas of research.
strategies for adding an extra dimension are illustrated in
Figures 5 and 6. The first uses 3D perspective to portray the
third dimension (Figure 5). The second uses shading, where
darker hues are used to represent either higher density or more See also: Cumulative (Combined Exposures) Risk Assessment;
central values (Figure 6). This is particularly useful for dis- Monte Carlo Analysis; Safety Pharmacology; Uncertainty
playing uncertainty, as the more probable parts of a curve are Analysis; Uncertainty Factors.
more defined.

Identifying Data Gaps and Planning Research


Further Reading
Putting a formal QRA together will inevitably raise areas of
uncertainty that can be addressed through further research. Carrington, C.D., Bolger, P.M., 2010. The limits of regulatory toxicology. Toxicol. Appl.
Pharmacol. 243, 191–197.
Since it has identified the issues that are important for the Carrington, C.D., Montwill, B., Bolger, P.M., 2004. An intervention analysis for the
decision, a risk assessment can be useful in planning the reduction of exposure to methylmercury from the consumption of seafood by
research that will have the most impact on future decisions. women of child-bearing age. Regul. Toxicol. Pharmacol. 40, 272–280.
644 Food Safety and Toxicology

Gaylor, D., Axelrad, J., Brown, R., et al., 1997. Human risk assessment prac- http://foodsafe.msu.edul – National Food Safety and Toxicology Center (at Michigan
tices in the US Food and Drug Administration. Regul. Toxicol. Pharmacol. 26, State University).
307–321. http://toxnet.nlm.nih.gov – TOXNET, Specialized Information Services, National Library
National Research Council, 1983. Risk Assessment in the Federal Government: of Medicine. Search for FoodSafety and Toxicology.
Managing the Process. National Academy of Science Press, Washington, DC. http://www.cfsan.fda.gov – US Food and Drug Administration, Toxicological Principles
for the Safety Assessment of Food Ingredients.

Relevant Websites

http://www.atsdr.cdc.gov – Agency for Toxic Substances and Disease Registry.


Toxicological Profile for FoodSafety and Toxicology.
http://www.who.int – Joint Expert Committee on Food Additives of the World Health
Organization and Food and Agriculture Organization, Environmental Health Criteria
70 - Principles for the safety assessment of food additives and contaminants in
food.
http://www.who.int/foodsafety/chem/principles/en/index1.html – Joint Expert
Committee on Food Additives of the World Health Organization and Food and
Agriculture Organization, Environmental Health Criteria 240 Principles and methods
for the risk assessment of chemicals in food.

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