Protective Action Criteria A Review

Alberta Health
Protective Action Criteria

A Review of Their Derivation, Use, Advantages
and Limitations
Public Health and Compliance
January 2017
Alberta Health, Health Protection Branch
Protective Action Criteria: A Review of Their Derivation, Use, Advantages and Limitations January 2017
About this document:

This technical document was prepared to provide background information for
health professionals who may use protective action criteria. The information
provided in this report is not intended to be used in place of jurisdiction-specific
guidelines for acceptable/ safe levels of chemical contaminants in any given
media (such as air, water, soil, fish, or wildlife). A plain-language document
summarizing this review is available online at:
http://open.alberta.ca/publications/9781460131220.
This document may be cited as follows:
Government of Alberta. (2017). Protective Action Criteria: A Review of Their Derivation, Use,
Advantages and Limitations. Environmental Public Health Science Unit, Health Protection
Branch, Public Health and Compliance Division, Alberta Health. Edmonton, Alberta.
Statement of Availability:
As part of the Government of Alberta’s commitment to open government, this
publication is posted to and permanently retained in the Open Government Portal
at http://open.alberta.ca/publications/9781460131213. Print copies are also
available.
ISBN: 978-1-4601-3121-3 (PDF)
ISBN: 978-1-4601-3120-6 (Print)
Copyright and Licence:

© Her Majesty the Queen in Right of Alberta, as represented by the Minister of
Alberta Health, 2017
This document is made available under the Open Government Licence – Alberta
(http://open.alberta.ca/licence).
Every effort has been made to provide proper acknowledgement of original

sources. If cases are identified where this has not been done, please notify
Alberta Health so appropriate corrective action can be taken.
For more information, please contact:

Health Protection Branch
Public Health and Compliance
Alberta Health
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10025 Jasper Avenue NW
Edmonton, Alberta, T5J 1S6 Canada
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Telephone: 780-427-4518 in Edmonton
or to be connected toll-free inside Alberta, dial 310-0000
© Her Majesty the Queen in Right of Alberta, as represented by the Minister of Alberta Health, 2017 i
Executive Summary
Protective action criteria (PACs) are emergency exposure guidelines that are used before or
during the unplanned release of a hazardous chemical in the air. The guidelines are intended
to protect the general public, including susceptible individuals such as infants, the elderly,
and those with illnesses, from health effects resulting from a rare one-time exposure to a
chemical. PACs are used prior to emergencies to estimate the toxic severity of potential
accident scenarios (hazard analysis or consequence analysis), or during chemical emergencies
to identify potential zones of impact (threat zones) and populations that may be at risk.
The main objectives of this report are to provide background information on PACs, present
a summary of real-world usage of PACs, and discuss the advantages and limitations
associated with these guidelines.
The PAC dataset is a consolidated list of 3 types of emergency exposure guidelines:
• Acute Exposure Guideline Levels (AEGLs); developed by the US Environmental
Protection Agency
• Emergency Response Planning Guidelines (ERPGs); developed by the American
Industrial Hygiene Association
• Temporary Emergency Exposure Limits (TEELs); developed by the US Department
of Energy
AEGLs and ERPGs are the preferred emergency guidelines, in that order, but are only
available for a limited number of chemicals. For chemicals without AEGLs or ERPGs,
TEELs are temporary guidelines used until AEGLs or ERPGs are developed. The PAC
dataset indicates whether a particular value is an AEGL, an ERPG, or a TEEL. PACs are
applicable to a 60-minute exposure duration (representing the total time of exposure).
Additionally, there are AEGLs for durations of 10 minutes, 30 minutes, 4 hours, and 8
hours.
PACs have 3 health effect levels based on severity of symptoms. Briefly, PAC-1 (which is
based on the corresponding AEGL-1, ERPG-1, or TEEL-1 value) is the threshold level for
mild, transient health effects; PAC-2 (based on AEGL-2, ERPG-2, or TEEL-2) is the
threshold level for irreversible or other serious health effects that could impair the ability to
take protective action; and PAC-3 (based on AEGL-3, ERPG-3, or TEEL-3) is the
threshold level for life-threatening health effects. Additionally, for TEELs, there is a TEEL-
0 value that represents the threshold level for no adverse effects.
The main difference between AEGLs, ERPGs, and TEELs is the method in which they are
derived. AEGL and ERPG development is a thorough and rigorous process involving
review of all primary source data. Because of this time-consuming process, AEGLs and
ERPGs have only been developed for ~270 (final, interim, and proposed) and ~145
substances, respectively. TEEL values, on the other hand, are based on secondary sources of
data (existing exposure limits) and require less time to develop. Thus, TEELs are available
for a large number of substances (> 3000), though are somewhat less reliable.
The types of groups or individuals using AEGLs, ERPGs, TEELs, and/or the PAC dataset
include emergency planning committees, emergency responders, toxicologists, industrial
hygienists, and risk assessors. Specific agencies that utilize these guidelines include
Environment Canada, Transport Canada, US Environmental Protection Agency, National
© Her Majesty the Queen in Right of Alberta, as represented by the Minister of Alberta Health, 2017 ii
Oceanic and Atmospheric Administration, US Department of Transportation, US

Department of Energy, US Department of Defense, Agency for Toxic Substances and
Disease Registry, American Chemistry Council, National Institute for Occupational Safety
and Health, and Occupational Safety and Health Administration.
PACs are typically combined with estimates of exposure concentrations (measured directly
and/or modeled using atmospheric dispersion modeling programs) to identify areas where a
chemical hazard exceeds a specified threshold level. The data can then be used to estimate
the severity of a chemical release, identify the potential health impact on the surrounding
communities, and assist in decision-making regarding emergency responses. Examples of
real-world applications for AEGLs, ERPGs, TEELs, and/or the PAC dataset as a whole
were found in reports of past chemical emergencies, hazard analysis (consequence analysis)
reports, and environmental impact assessments. Most accounts were related to the specific
use of AEGLs and ERPGs, rather than the PAC dataset itself. Additionally, references to
the usage of TEEL values were few in number. This is likely because AEGLs and ERPGs
are available for commonly used chemicals that are more likely to be involved in a chemical
accident, and AEGLs and ERPGs are considered more reliable and scientifically sound than
TEELs.
Advantages of PACs include:
• The PAC dataset provides emergency inhalation exposure guidelines for ~3400
substances to assist in the management of chemical emergencies.
• They are intended to be protective for most of the general public including susceptible
populations.
• Development of AEGL and ERPG values involves an analysis of all available
toxicological data and a rigorous review process. AEGLs and ERPGs are peer-
reviewed.
• TEEL values are derived using existing exposure guidelines or toxicity data and can
be developed relatively quickly. In the absence of AEGLs or ERPGs, TEELs can be
a useful source of information.
• PAC values have been incorporated into several atmospheric dispersion modeling
programs.
Limitations of PACs include:
• AEGLs and ERPGs are available for a relatively small number of chemicals. The
extensive review process involved in AEGL and ERPG derivation requires a
significant amount of time and resources.
• TEEL values are not peer-reviewed and are considered less reliable than AEGLs and
ERPGs.
• When using the consolidated PAC dataset, only one exposure duration is available (1
hour), which can lead to some confusion when actual exposure times are shorter or
longer. This is particularly important for chemicals that do not have an AEGL (with
a range of exposure durations) to refer to.
• Uncertainties in atmospheric modeling may lead to under- or over-estimations of
threat zones and potentially cause problems during an emergency (e.g., evacuation
areas are too small or too large). Users of the atmospheric modeling software
© Her Majesty the Queen in Right of Alberta, as represented by the Minister of Alberta Health, 2017 iii
programs should be properly trained and have a thorough understanding of the

capabilities and limitations of the program
• PACs are not directly applicable to releases of chemical mixtures, as the potential
additive, synergistic, or antagonistic effects that may result from exposure to multiple
chemicals are not accounted for. Chemicals in combination may behave differently
than when alone, and predicting the toxic potential of a mixture is often very
difficult. A chemical mixture methodology is available for estimating the potential
health impact of exposures involving multiple chemicals.
In summary, PACs are an important source of information for emergency planning and
emergency response, providing toxic endpoint values that can be used to determine threat
zones and estimate potential health impacts on a surrounding population. AEGLs and
ERPGs are the preferred guidelines for use prior to or during a chemical emergency.
However, TEELs can also be valuable when a chemical emergency occurs involving a
substance with no AEGL or ERPG available.
© Her Majesty the Queen in Right of Alberta, as represented by the Minister of Alberta Health, 2017 iv
Acknowledgements
This report was prepared by:
Adrienne LeBlanc Environmental Health Consultant
With contributions from:
Merry Turtiak Alberta Health

Brendan Schiewe Alberta Health
Special thanks to our peer-reviewers for their valuable editorial comments:
Jennifer Graydon Alberta Health

Ludmilla Rodriguez Alberta Health Services
Lynn Que Alberta Health Services
Debra Hopkins Alberta Environment and Parks
Martin Bundred Alberta Environment and Parks
Bob Myrick Alberta Environment and Parks
Laura Blair Alberta Environment and Parks
Zak Semaine Alberta Energy Regulator
Michael Zelensky Alberta Energy Regulator
Déirdre Treissman Blue House Environmental Consulting
© Her Majesty the Queen in Right of Alberta, as represented by the Minister of Alberta Health, 2017 v
Table of Contents
Executive Summary ......................................................................................................ii
Abbreviations ............................................................................................................. viii
1. Introduction ...........................................................................................................1
2. Background Information on the Protective Action Criteria ................................ 2
2.1 Acute Exposure Guideline Levels (AEGLs) ..................................................................... 2
2.1.1 Definitions of AEGLs ................................................................................................................. 2
2.1.2 Derivation of AEGLs.................................................................................................................. 3
2.2 Emergency Response Planning Guidelines (ERPGs)..................................................... 4
2.2.1 Definitions of ERPGs ................................................................................................................ 4
2.2.2 Derivation of ERPGs ................................................................................................................. 5
2.3 Temporary Emergency Exposure Limits (TEELs) ........................................................... 5
2.3.1 Definitions of TEELs .................................................................................................................. 5
2.3.2 Derivation of TEELs .................................................................................................................. 6
2.4 Comparison of AEGLs, ERPGs, and TEELs ................................................................... 8
3. Comparisons with Other Air Guideline Levels .................................................. 10
4. Usage of Protective Action Criteria .................................................................... 11
4.1 Agencies Utilizing Protective Action Criteria ................................................................. 15
4.1.1 Canada ....................................................................................................................................15
4.1.2 USA ..........................................................................................................................................15
4.1.3 Worldwide ................................................................................................................................16
4.2 Past Chemical Emergency Events ................................................................................ 17
5. Advantages and Limitations of the Protective Action Criteria ......................... 21
6. Summary ..............................................................................................................23
7. References ...........................................................................................................24
Appendix: Summary of Guidelines for H2S ............................................................... 31
© Her Majesty the Queen in Right of Alberta, as represented by the Minister of Alberta Health, 2017 vi
List of Figures
Figure 1: An image of ALOHA toxic threat zones, indicating where pollutant
concentrations are higher or lower than the chosen levels of concern (LOC). AEGLs are
presented and the red (centre) threat zone is the most hazardous (AEGL-3) [34] ......... 14
List of Tables
Table 1: Criteria used for selection of health endpoints for derivation of AEGL-1,
AEGL-2, and AEGL-3 values (in order of priority) [9] ....................................................... 3
Table 2: Hierarchy of selection of toxicity parameters used for TEEL development (in
order of priority for each health effect tier) [1] .................................................................. 7
Table 3: Comparison of AEGLs, ERPGs, and TEELs (modified from [12]) ...................... 9
Table 4: Comparison of various air guideline levels ....................................................... 11
Table 5: Examples of protective action criteria (PACs) usage in consequence analyses
(white literature) ............................................................................................................18
Table 6: Examples of protective action criteria (PACs) usage in consequence analyses
in environmental impact assessments (grey literature) .................................................. 19
Table 7: Summary of H2S guideline values from various jurisdictions ............................ 31
© Her Majesty the Queen in Right of Alberta, as represented by the Minister of Alberta Health, 2017 vii
Abbreviations
AAQO: Ambient air quality objective
ACGIH: American Conference of Governmental Industrial Hygienists
AEGL: Acute exposure guideline level
AIHA: American Industrial Hygiene Association
ALOHA: Areal location of hazardous atmospheres
ATSDR: Agency for Toxic Substances and Disease Registry
CAMEO Computer-aided management of emergency operations
CA-REL: Reference exposure level (California)
CASRAM Chemical accident statistical risk assessment model
CEGL: Continuous exposure guidance level
CEI: Chemical exposure index
CMM: Chemical mixture methodology
CSEPP: Chemical stockpile emergency preparedness program
DOE: Department of Energy (US)
E2 Regulations:
Environmental Emergency Regulations (Canada)
EEGL: Emergency exposure guidance level
ERPG: Emergency response planning guideline
HSDB: Hazardous substances data bank
IDLH: Immediately dangerous to life or health
IMAAC: Interagency Modeling and Atmospheric Assessment Center
LEL: Lower explosive limit
LC50: Lethal concentration in 50% of a sample
LCLO: Lethal concentration - lowest
LOAEL: Lowest-observed-adverse-effect level
LOC: Level of concern
MAK: Maximale arbeitsplatz-konzentration [Maximum concentrations at the
workplace] (Germany)
MRL: Minimal risk level
NAC/AEGL: National Advisory Committee for Acute Exposure Guideline Levels for
Hazardous Substances
NAS: National Academy of Sciences
NHSRC: National Homeland Security Research Center
NIOSH: National Institute for Occupational Safety and Health
NOAEL: No-observed-adverse-effect level
OEHHA: Office of Environmental Health Hazard Assessment (California)
OSHA: Occupational Safety and Health Administration
PAC: Protective action criteria
PAL: Provisional advisory level
PEL: Permissible exposure limit
PHAST Process hazard analysis software tool
REL: Recommended exposure limit
RfC: Reference concentration
RTECS: Registry of toxic effects of chemical substances
SCAPA: Subcommittee on Consequence Assessment and Protective Actions
STEL: Short-term exposure limit
TCLO: Toxic concentration - lowest
© Her Majesty the Queen in Right of Alberta, as represented by the Minister of Alberta Health, 2017 viii
TDLO: Toxic dose - lowest

TEEL: Temporary emergency exposure limit
TERA: Toxicology Excellence for Risk Assessment
TLV: Threshold limit value
TWA: Time-weighted average
USEPA: United States Environmental Protection Agency
WEEL: Workplace environmental exposure level
© Her Majesty the Queen in Right of Alberta, as represented by the Minister of Alberta Health, 2017 ix
1. Introduction
Protective action criteria (PACs) are emergency inhalation exposure guidelines used in the
planning for and response to unplanned releases of a hazardous chemical in the air. PACs
are set by the US Department of Energy (DOE) and are defined as the "threshold
concentration of a chemical in air at which protective action is required" [1]. The PAC
dataset is a consolidated list of 3 types of emergency exposure guidelines: Acute Exposure
Guideline Levels (AEGLs, developed by the US Environmental Protection Agency
(USEPA)), Emergency Response Planning Guidelines (ERPGs, developed by the American
Industrial Hygiene Association (AIHA)), and Temporary Emergency Exposure Limits
(TEELs, developed by the DOE) [2].
PACs are used by government agencies and the private sector to evaluate the potential
impact of a one-time rare exposure to a chemical. Atmospheric concentrations of the
chemical (either measured or modeled) can be used in conjunction with PAC values to
identify threat zones. A threat zone is defined as the geographical area where the
concentration of a chemical hazard exceeds a specified level of concern (LOC) [3]. The
threat zone data can be used to estimate the severity of a chemical release, identify the
potential health impact on the surrounding communities, and assist in decision-making
regarding emergency responses (e.g., evacuations, shelter-in-place) [1]. This information is
used for emergency planning prior to a chemical event (hazard analysis or consequence
analysis) or emergency response during a chemical accident.
The objectives of this report are to:
1. Provide background information on PACs (definitions, derivation of PAC values);
2. Present a summary of real-world usage of PACs;
3. Discuss the advantages and limitations associated with PACs
A literature search was conducted for white and grey material (studies, reports, news articles,
websites) that discussed the development and usage of AEGLs, ERPGs, TEELs, and PACs.
Scientific databases (Scopus, Pubmed) and internet search engines (Google) were used for the
searches. The search terms included protective action criteria (or PACs), acute exposure
guideline level(s) (or AEGLs), emergency response planning guideline(s) (or ERPGs), and
temporary emergency exposure limit(s) (or TEELs). The search was generally limited to data
published in 2005 or later; however, earlier publications were included if considered
particularly relevant.
© Her Majesty the Queen in Right of Alberta, as represented by the Minister of Alberta Health, 2017 1
2. Background Information on the Protective

Action Criteria
PACs are made up of 3 types of emergency exposure guidelines: AEGLs, ERPGs, and
TEELs. AEGLs and ERPGs are the preferred emergency guidelines, in that order, but are
only available for a limited number of chemicals. For chemicals without AEGLs or ERPGs,
TEELs are the temporary guidelines to be used until AEGLs or ERPGs are developed. The
PAC dataset indicates whether a particular value is an AEGL, an ERPG, or a TEEL [4].
PACs are applicable to an exposure duration of 60-minutes (total exposure time).
Additionally, there are AEGLs for durations of 10 minutes, 30 minutes, 4 hours, and 8
hours. The current PAC dataset, last updated in February of 2012 and available online,
includes exposure guidelines for ~3400 chemicals [4]. There are currently AEGLs for ~270
chemicals (final (131), interim (130), and proposed (12)), ERPGs for ~145 chemicals, and
TEELs for over 3000 chemicals [4,5,6].
For each guideline, there are 3 health effect levels based on severity of symptoms. Briefly,
PAC-1 (which is based on the corresponding AEGL-1, ERPG-1, or TEEL-1 value) is the
threshold level for mild, transient health effects; PAC-2 (based on AEGL-2, ERPG-2, or
TEEL-2) is the threshold level for irreversible or other serious health effects that could
impair the ability to take protective action; and PAC-3 (based on AEGL-3, ERPG-3, or
TEEL-3) is the threshold level for life-threatening health effects [7]. Additionally, for
TEELs, there is a TEEL-0 value that represents the threshold level for no adverse effects.
Specific definitions for each health effect level for AEGLs, ERPGs, and TEELs, as well as
summaries of the methods for guideline derivation, are presented in Sections 2.1 to 2.3.
2.1 Acute Exposure Guideline Levels (AEGLs)
2.1.1 Definitions of AEGLs

AEGLs are developed by the National Advisory Committee for Acute Exposure Guideline
Levels for Hazardous Substances (NAC/AEGL) of the USEPA. AEGLSs are emergency
exposure guidelines intended for the general public including susceptible populations (which
the NAC/AEGL identifies as infants, children, the elderly, persons with asthma, and those
with other illnesses) [8]. Guidelines are derived for 5 exposure durations (total exposure
time): 10 minutes, 30 minutes, 60 minutes, 4 hours, and 8 hours.
The 3 health effect tiers for AEGLs are defined as follows:
AEGL-1: the airborne concentration of a substance above which it is predicted that
the general population, including susceptible individuals, could experience
notable discomfort, irritation, or certain asymptomatic nonsensory effects.
However, the effects are not disabling and are transient and reversible upon
cessation of exposure.
AEGL-2: the airborne concentration of a substance above which it is predicted
that the general population, including susceptible individuals, could
experience irreversible or other serious, long-lasting adverse health effects or
an impaired ability to escape.
AEGL-3: the airborne concentration of a substance above which it is predicted

experience life-threatening health effects or death.
Regarding susceptible individuals, the NAC/AEGL stated that "these exposure limits
are intended to protect most individuals in the general population, including those that
might be particularly susceptible to the deleterious effects of the chemicals...It is
recognized that certain individuals, subject to unique and idiosyncratic responses,
could experience effects at concentrations below the corresponding AEGLs" [9].
2.1.2 Derivation of AEGLs

The methodology for AEGL development is the most comprehensive of the 3 emergency
guidelines (AEGLs, ERPGs, TEELs) [9]. It involves both the NAC/AEGL (which includes
members from federal and state governments, international governments, academia and
other organizations, labour unions, and private industry) and the National Academy of
Sciences (NAS). The process includes an in-depth scientific literature search and preparation
of a technical support document, followed by a rigorous public and peer review.
AEGL values for each tier are derived using data from key toxicity studies (primary
reference sources only) obtained in the literature search [9]. The criteria used for selection of
health endpoints for AEGL derivation are summarized in Table 1. Criteria are presented in
order of preference for each AEGL tier, and examples of specific health endpoints that have
been used to establish AEGL values are also provided. Briefly, the highest concentration
from animal or human exposures that does not elicit the effects defined by a specific AEGL
tier (the no-observed-adverse-effect level (NOAEL)) is the preferred starting point for
derivation of an AEGL value. When a NOAEL is not available, the lowest-observed-
adverse-effect level (LOAEL) for a response is the second choice as the starting point. For
AEGL-2, when neither a NOAEL nor LOAEL is available, the AEGL-2 value may be
calculated as a fraction (typically one-third) of the AEGL-3.
Development of AEGLs typically involves extrapolation methods and use of uncertainty
factors and/or modifying factors. For example, exposure-time extrapolations are used in
AEGL development when toxicology studies utilize exposure durations that differ from the
AEGL exposure durations (10 min, 30 min, 60 min, 4 hr, 8 hr). Additionally, interspecies
and intraspecies uncertainty factors are incorporated into AEGLs to account for the
differences in biological response between animals and humans, and the variation in
response within a human population. Likewise, modifying factors may also be incorporated
into AEGLs to account for incomplete information or uncertainties in the overall database.
Details on the methodology for selection of values for uncertainty or modifying factors are
provided in the Standard Operating Procedures for AEGL development [9].
Table 1: Criteria used for selection of health endpoints for derivation

of AEGL-1, AEGL-2, and AEGL-3 values (in order of priority) [9]
AEGL
Criteria used for selection of health endpoints
Level
AEGL-1 1. Highest experimental exposure without an AEGL-1 effect (NOAEL)
e.g., sensory irritation, altered pulmonary function, narcosis in humans
AEGL
Criteria used for selection of health endpoints
Level
2. Effect level for a response (LOAEL)
e.g., odour detection, mild sensory irritation, methemoglobin formation (22%),
transient changes in pulmonary function
3. No value established
(due to insufficient data or because levels that are 'detectable' approach or exceed
an AEGL-2 value)
AEGL-2 1. Highest experimental exposure without an AEGL-2 effect (NOAEL)
e.g., decreased hematocrit, kidney pathology, behavioral changes
2. Effect level for a response that was not incapacitating or not irreversible (LOAEL)
e.g., overt ocular or respiratory irritation, dyspnea, pulmonary function changes,
provocation of asthma episodes, respiratory tract pathology, mild narcosis,
methemoglobin formation (40%)
3. A fraction (typically one-third) of the AEGL-3 value
AEGL-3 1. Highest exposure level that does not cause lethality (NOAEL)
2. Effect level for a severe response (LOAEL)
e.g., decreased hematocrit, methemoglobin formation (70-80%), cardiac
pathology, severe respiratory pathology
2.2 Emergency Response Planning Guidelines (ERPGs)
2.2.1 Definitions of ERPGs

ERPGs are emergency inhalation exposure guidelines developed by the AIHA [10]. ERPGs
are derived for 1-hour exposure durations, and the 3 health severity levels are defined as
follows:
ERPG-1: the maximum airborne concentration below which it is believed nearly all
individuals could be exposed for up to 1 hour without experiencing other
than mild, transient adverse health effects or without perceiving a clearly
defined objectionable odour.
individuals could be exposed for up to 1 hour without experiencing or
developing irreversible or other serious health effects or symptoms that could
impair an individual's ability to take protective action.
individuals could be exposed for up to 1 hour without experiencing or
developing life-threatening health effects.
The AIHA provided the following statement regarding the target population (i.e.,
‘nearly all individuals’) for ERPGs [11]:
“The values derived for ERPGs should not be expected to protect everyone but should be applicable to most
individuals in the general population. In all populations there are hypersensitive individuals who will show
adverse responses at exposure concentration below levels where most individuals normally would respond.
Furthermore, since these values have been derived as planning and emergency response guidelines, not exposure
guidelines, they do not contain the safety factors sometimes incorporated into exposure guidelines. Instead, they
are estimates, by the committee, of the thresholds above which there would be an unacceptable likelihood of
observing the defined effects.”
2.2.2 Derivation of ERPGs

ERPGs are developed in a similar manner to AEGLs; the process includes a comprehensive
literature search, preparation of a technical support document, and committee and public
reviews [11]. Draft ERPG documents may be prepared by any person, agency, organization,
or group desiring a peer-reviewed ERPG for a specific chemical; the documents and ERPG
values are then reviewed by the Emergency Response Planning Committee.
Original source toxicity data, preferentially from human and animal acute inhalation studies,
are used to derive ERPGs using a weight-of-evidence approach [10]. The highest
experimental levels not showing the effects defined by the ERPG tier (the NOAEL) is used
for ERPG derivation. For all ERPG tiers, a default uncertainty factor of 10 is applied for
interspecies extrapolation, with lesser or greater factors used when the data are sufficient or
insufficient, respectively. The AIHA also state that additional uncertainty factors are to be
applied when data are insufficient or when there are individuals in the population that are
unusually sensitive to a particular chemical; no further details were provided regarding the
use of these uncertainty factors [10,11].
The AIHA indicated that the 1-hour exposure duration for ERPGs was chosen based on the
availability of toxicity data and the exposure time that would be most relevant for emergency
planning [10]. Shorter exposure durations for an ERPG can be established upon request and
when justified.
If applicable, ERPG values also include an odour detection symbol for chemicals with an
odour that is likely to be detectable near the ERPG-1 value [10]. Also indicated with some
ERPG values are lower explosive limit (LEL) warnings to serve as an alert for a potential
physical explosion hazard.
2.3 Temporary Emergency Exposure Limits (TEELs)
2.3.1 Definitions of TEELs

TEELs, developed by the DOE Subcommittee on Consequence Assessment and Protective
Actions (SCAPA), are emergency exposure guidelines intended for use when no AEGL or
ERPG value is available [1]. TEEL values are considered to be protective of the general
population including susceptible individuals (identified as infants, children, the elderly,
persons with asthma, and those with other illnesses). The 2008 DOE Handbook
recommends exposure durations of 15 minutes for TEEL values [1]; however, 60-minute
exposure durations are often used [12,13]. The SCAPA group website states that TEELs
would be standardized to 1-hour durations in the near future (no date is provided) [14].
There are 4 health severity levels for TEELs [13,15]:
TEEL-0: the threshold concentration below which most people will experience no
appreciable risk of health effects.
TEEL-1: the airborne concentration of a substance above which it is predicted that
the general population, including susceptible individuals, could experience
notable discomfort, irritation, or certain asymptomatic nonsensory effects.

However, the effects are not disabling and are transient and reversible upon
cessation of exposure.
TEEL-2: the airborne concentration of a substance above which it is predicted
experience irreversible or other serious, long-lasting adverse health effects or
an impaired ability to escape.
TEEL-3: the airborne concentration of a substance above which it is predicted
experience life-threatening health effects or death.
It is interesting to note that the target population in the TEEL-0 definition (‘most
people’) differs from that of the other TEEL definitions (‘susceptible individuals’). No
further information was given in the DOE Handbook regarding the intended meaning
of ‘most people’ in the definition of TEEL-0 [1].
2.3.2 Derivation of TEELs

TEELs undergo a less rigorous review process than AEGLs and ERPGs, and are only to be
used until AEGLs or ERPGs are developed [1]. The goal of TEEL development is to derive
limits in a timely manner while maintaining high quality. To accomplish this, the DOE
utilizes secondary data sources as the basis for TEELs. Secondary data sources include
existing exposure limits from other agencies (e.g., Permissible Exposure Limits (PELs),
Threshold Limit Values (TLVs), Immediately Dangerous to Life or Health concentrations
(IDLHs), Recommended Exposure Limit (RELs)), or alternatively, experimentally-derived
toxicity parameters (e.g., LC50 (lethal concentration in 50% of a sample), LCLO (lethal
concentration lowest), TCLO (toxic concentration lowest), TDLO (toxic dose lowest). The
DOE has developed a hierarchy for selection of toxicity parameters and sources to be used
for TEEL development (Table 2). Existing exposure limits are the ideal source of
information; for example, the 8-hour time-weighted average PEL is the first choice for
derivation of a TEEL-0 value.
The DOE provides the following explanation for their use of occupational guideline levels
as general public emergency guidelines [1]:
“Typically, employed persons are healthy adults exposed during working hours so that limits to protect the
general public for longer than a typical work shift should be more stringent. TEEL-0 limits, for example,
which assume a 15-minute time-weighted average (TWA) concentration, are determined using the 8-hour
TWA Permissible Exposure Limit (PEL) value designed for occupational exposure. This value is
conservative because the exposure time is short compared with the 8-hour workday.”
The DOE Handbook states that similar considerations are involved in the development of
TEEL values for other tiers; however, no further information was provided [1].
For several chemicals, there are no existing exposure limits. In these cases, experimentally-
derived toxicity parameters are used as the starting point for development of TEELs. For
example, TCLO and TDLO are to be used for TEEL-2 development when no other existing
exposure guidelines are available (Table 2). The main sources for toxicity data are the
Registry of Toxic Effects of Chemical Substances (RTECS), Sax's Dangerous Properties of
Industrial Chemicals, and the Hazardous Substances Data Bank (HSDB), though toxicity
data can be obtained from other sources as well. The final TEEL values also incorporate
adjustments for animal-human extrapolations, time extrapolations, and route of exposure

extrapolations. A detailed methodology for deriving TEELs from toxicity data is provided in
the DOE Handbook [1].
In developing TEELs for chemicals with no exposure limits and absent/insufficient toxicity
parameters, toxicity can be estimated based on other structurally similar chemicals for which
there are data (Structure-Activity Relationships) [1]. TEELs may also be derived from Health
Hazard Ratings (e.g., Sax Hazard Rating) or using TEEL values from other tiers.
Table 2: Hierarchy of selection of toxicity parameters used for TEEL

development (in order of priority for each health effect tier) [1]
TEEL Hierarchy of Toxicity Parameters (in order of Source of Data
Tier preference)
TEEL-0 PEL-TWA (Permissible Exposure Limit - TWA) OSHA
TLV-TWA ACGIH
(Threshold Limit Value - TWA)
REL-TWA NIOSH
(Recommended Exposure Limit - TWA)
WEEL-TWA AIHA
(Workplace Environmental Exposure Level - TWA)
MAK-TWA (Maximale Arbeitsplatz-Konzentration) Deutsche
Forschungsgemeinschaft
(German Research
Foundation)
Other-TWA (TWA from other sources) Other sources
CEGL (Continuous Exposure Guidance Level) National Academy of Sciences
TEEL-1 PEL-STEL (Permissible Exposure Limit - STEL) OSHA
TLV-STEL ACGIH
(Threshold Limit Value - STEL)
REL-STEL NIOSH
(Recommended Exposure Limit - STEL)
WEEL- AIHA
(Workplace Environmental Exposure Level - STEL)
STEL
Other-STEL Other sources
(STEL from other sources)
TLV-TWA x ACGIH
(Threshold Limit Value - TWA multiplied by 3)
3
TEEL-2 EEGL (60- (Emergency Exposure Guidance Level) National Academy of Sciences
min)
LOC USEPA, US Department of
(Level of Concern)
Transportation
PEL-C OSHA
(Permissible Exposure Limit - ceiling)
TLV-C ACGIH
(Threshold Limit Value - ceiling)
REL-C NIOSH
(Recommended Exposure Limit - ceiling)
WEEL-C AIHA
(Workplace Environmental Exposure Level - ceiling)
TLV-TWA x ACGIH
(Threshold Limit Value - TWA multiplied by 5)
5
TCLO RTECS, Sax, HSDB, or other
(Toxic Concentration Lowest)
sources
TDLO RTECS, Sax, HSDB, or other
(Toxic Dose Lowest)
sources
TEEL Hierarchy of Toxicity Parameters (in order of Source of Data

Tier preference)
TEEL-3 EEGL (30- (Emergency Exposure Guidance Level) National Academy of Sciences
min)
IDLH NIOSH
(Immediately Dangerous to Life or Health)
LC50 RTECS, Sax, HSDB, or other
(Lethal Concentration 50%)
sources
LCLO RTECS, Sax, HSDB, or other
(Lethal Concentration Lowest)
sources
LD50 RTECS, Sax, HSDB, or other
(Lethal Dose 50%)
sources
LDLO RTECS, Sax, HSDB, or other
(Lethal Dose Lowest)
sources
Abbreviations: ACGIH: American Conference of Governmental Industrial Hygienists; AIHA: American Industrial Hygiene
Association; HSDB: Hazardous Substances Data Bank; OSHA: Occupational Safety and Health Administration; NIOSH:
National Institute for Occupational Safety and Health; RTECS: Registry of Toxic Effects of Chemical Substances
(RTECS); Sax: Sax's Dangerous Properties of Industrial Chemicals; STEL: short-term exposure limit; TWA: time-weighted
average
2.4 Comparison of AEGLs, ERPGs, and TEELs

AEGLs, ERPGs, and TEELs all serve the same purpose by providing exposure guideline
levels for hazardous chemicals that can be used in emergency situations. However, the
guidelines are developed by different agencies and are derived in different ways [12,14].
AEGLs, ERPGs, and TEELs also differ in their exposure durations and in their definitions
of health effect levels and target populations. A comparison of the guidelines is presented in
Table 3.
With regards to guideline derivation, AEGL and ERPG development is a rigorous and time-
consuming process involving review of all primary source data. AEGL values are derived
using data from a key toxicology study, while ERPG values are derived using data from
multiple studies and a weight-of-evidence approach. Contrarily, TEEL values are derived
using secondary sources of data (e.g., existing exposure limits) and require much less time to
develop. TEELs are intended to be temporary, only to be used until AEGLs or ERPGS are
developed [1].
While AEGLs, ERPGs, and TEELs are all intended to be protective for most individuals in
a population, none of the guidelines are designed to be protective of hypersensitive
individuals [1]. Hypersensitive individuals are defined as those whose reactions to chemical
exposure are unique and idiosyncratic and lie outside the range of distributions expected for
the general population including susceptible subpopulations [9]. Examples of hypersensitive
individuals include those with severely debilitating pulmonary, hepatic, or renal disorders, the
elderly with serious debilities of primary physiologic systems, and those with unique
hypersensitivities to specific chemicals or chemical classes.
Table 3: Comparison of AEGLs, ERPGs, and TEELs (modified from

[12])
AEGL ERPG TEEL
Publishing agency USEPA/NAS AIHA DOE
Number of chemicals 131 (final) 145 >3000
with published values 130 (interim)
12 (proposed)
Exposure duration 10 min, 30 min, 60 min 15 min*
60 min, 4 hr, 8 hr 60 min**
Target population General population Nearly all individuals General population
including susceptible including susceptible
individuals individuals
Method of guideline Key study from primary Weight-of-evidence Use of secondary data
derivation data sources approach from primary sources (existing exposure
data sources limits and toxicity data)
Peer-reviewed Yes Yes No
* The DOE Handbook recommends an exposure duration of 15 min for TEELs [1]; ** Other
sources indicate a 60-minute exposure duration for TEELs [12,13].
3. Comparisons with Other Air Guideline Levels

In addition to PACs, there are several other guideline levels that exist for airborne chemicals,
such as Ambient Air Quality Objectives (AAQOs), Minimal Risk Levels (MRLs), Reference
Concentration (RfCs), PELs, RELs, and TLVs, and Workplace Environmental Exposure
Levels (WEELs). The definitions and purposes of these guidelines vary, with each having a
specified duration of exposure, frequency of exposure, and target population; a comparison
of the guidelines is presented in Table 4.
PACs are similar to Provisional advisory levels (PALs) in that they are both used to assist in
emergency planning for the general public [16,17]. Both guidelines have 3 health effect levels
with similar definitions; however, PACs are intended for acute exposures of 1 hour (or up to
8 hours for chemicals with AEGLs) while PALs are for longer term exposures of 24 hours
to 2 years (Table 4a).
The primary difference between PACs and the public health guidelines (e.g., AAQOs,
MRLs, RfCs) is related to the frequency of exposure (i.e., acute single exposure vs chronic
(continuous/repeated) exposure) (Table 4b). PACs are guidelines for a single acute exposure
during a chemical emergency; a 1-hr PAC value refers to a total exposure time of 1 hour as
well as an averaging period of 1 hour. Conversely, public health guidelines are for
continuous or repeated exposures to ambient pollutants over a lifetime; these guidelines have
various averaging periods ranging from 1 hour to 1 year. For example, a 1-hr AAQO value
refers to an exposure concentration averaged over 1-hour and assumes the total exposure
time to be continuous (lifetime).
The main difference between PACs and occupational exposure guidelines (e.g., IDLHs,
PELs, TLVs) is the target population. PACs are guidelines for the general public, while
occupational guidelines are intended for healthy adult workers (Table 4c). Additionally,
several occupational guidelines (PELs, RELs, TLVs, WEELs) account for both single and
repeated exposures to a chemical over a working lifetime, while PACs are for single
exposures of 1 hour (or up to 8 hours for AEGLs).
To illustrate the variation in guidance values for a specific chemical, a summary of guideline
levels for hydrogen sulfide is presented in Appendix A [18].
4. Usage of Protective Action Criteria

The groups or individuals that typically make use of PACs include [10]:
• Government agencies
• Industrial hygienists
• Fire Protection Specialists
• Air dispersion modelers
• Emergency responders
• Risk assessors and risk managers
• Community action emergency response participants
• Toxicologists
• Transportation safety engineers
• Local emergency planning committees
• Industrial process safety engineers
• State emergency response commissions
• Resources conservation and recovery act managers
Table 4: Comparison of various air guideline levels

Guideline Definition Exposure Exposure Developed
Single/ Averaging By
Repeated Time
a. Emergency Guidelines (for the general public)
Protective Action Emergency guidelines intended to protect the Single 1 hr AIHA,
Criteria (PAC) general public from rare, unanticipated, short- exposure [total exposure DOE,
term chemical exposures. The chemical time] USEPA
concentration in air at which protective [1,10]
action is required
Provisional A tiered set of exposure values used to Repeated 24 hr, 30 day, NHSRC [16]
Advisory Level inform risk-based decision making during a exposure 90 day, 2 year
(PAL-1, PAL-2, response to environmental release of
PAL-3) hazardous chemicals; they are longer term
emergency advisory levels for the general
public, including sensitive individuals, for
contaminated air and water exposures
b. Public Health Guidelines (for the general public)
Alberta Ambient Levels intended to protect the environment Repeated 1 hr, 24 hr, Government
Air Quality and human health to an extent technically exposure Annual of Alberta
Objective and economically feasible, as well as socially (8 hr, 3 day, 30 [19]
(Alberta AAQO) and politically acceptable day also used
occasionally)
Canadian Health-based air quality objectives for Repeated 8 hr, 24 hr, Environmen
Ambient Air pollutant concentrations in outdoor air exposure Annual t Canada /
Quality Standard [beginning in 2015] Health
(CAAQS) Canada [20]
National National goal for outdoor air quality that Repeated 1 hr, 8 hr, 24 hr, Environmen
Ambient Air protects public health, the environment, or exposure Annual t Canada /
Quality Objective aesthetic properties of the environment Health

Repeated Time
(NAAQO) Canada [21]
National Maximum permissible concentrations for Repeated 1 hr, 3 hr, 8 hr, USEPA [22]
Ambient Air criteria pollutants; designed to provide public exposure 24 hr, 3 month,
Quality Standard health protection (including sensitive Annual
(NAAQS) individuals) and public welfare protection
(including decreased visibility and damage to
animals, crops, vegetation, and buildings)
Minimal Risk Estimate of daily exposure to a hazardous Repeated acute (1-14 ATSDR [23]
Level (MRL) substance at or below which that substance is exposure days),
unlikely to pose a measurable risk of harmful, intermediate
noncancerous effects (>14-364 days),
chronic (365+
days)
Reference Daily inhalation exposure to the human Repeated acute (≤24 hr), USEPA [24]
Concentration population (including sensitive subgroups) exposure short-term
(RfC) that is likely to be without an appreciable risk (>24 hr-30
of deleterious effects during a lifetime days),
subchronic
(30+ days)
Reference Concentration of a chemical at or below Repeated 1 hr, 8 hr, OEHHA
Exposure which adverse noncancer health effects are exposure Annual (California)
Level (CA-REL) not anticipated to occur for a specified [25]
duration
c. Occupational Exposure Guidelines (for healthy workers)
Continuous A ceiling concentration of a chemical in air to Repeated 90 days NAS [26]
Exposure which personnel can be exposed for up to 90 exposure
Guidance Level days without immediate or delayed adverse
(CEGL) effects or degradation of performance
Emergency Air concentration of a substance that is Single 1 to 24 hr NAS [26]
Exposure acceptable for the performance of specific exposure [total exposure
Guidance Level tasks during rare emergencies usually lasting time]
(EEGL) from 1 to 24 hours (i.e., a ceiling guidance
level for a single emergency exposure)
Immediately Airborne contaminant exposure that is likely Single 30 min NIOSH [27]
Dangerous to to cause death or immediate or delayed exposure [total exposure
Life or Health permanent adverse health effects or prevent time]
(IDLH) escape from such an environment
Permissible Regulatory limits on the concentration of a Single and 15-30 min OSHA [28]
Exposure Limit substance in the air to protect workers against repeated (STEL),
(PEL) the health effects of exposure to hazardous exposure 8-hr TWA,
substances Ceiling
Recommended Level of hazardous substance in the Single and 15 min (STEL), NIOSH [29]
Exposure Limit workplace believed to be protective of repeated 10-hr TWA,
(REL) worker safety and health over a working exposure Ceiling
lifetime
Threshold Limit Concentration at which it is believed that Single and 15 min (STEL), ACGIH [30]
Value (TLV) nearly all workers may be repeatedly exposed repeated 8-hr TWA,

Repeated Time
without adverse health effects exposure Ceiling
Workplace Level protecting most workers from adverse Single and 15 min (STEL), AIHA,
Environmental health effects related to occupational repeated 8-hr TWA, TERA
Exposure Level chemical exposures exposure Ceiling [31,32]
(WEEL)
Abbreviations: AIHA: American Industrial Hygiene Association; ATSDR: Agency for Toxic Substances and Disease
Registry; DOE: US Department of Energy; NHSRC: National Homeland Security Research Center; OEHHA: Office of
Environmental Health Hazard Assessment (California); USEPA: US Environmental Protection Agency.
When responding to or planning for a chemical emergency, field measurements and/or

atmospheric modeling are used to estimate the atmospheric concentrations of the chemical
in the surrounding area. Atmospheric dispersion models provide computerized estimates of
the direction and speed of a chemical plume. The dispersion models take into account
several factors that influence the spread of the plume over time, such as rate of chemical
release, volatility, wind speed and direction, temperature, and terrain. Field measurements, if
they are available, may also be incorporated into the computerized models to improve
concentration estimates. Based on the measured and/or modeled concentrations, threat
zones can be estimated using PAC values as the toxic LOC.
There are a number of atmospheric modeling software programs that utilize PACs. The
most commonly used program is CAMEO/ALOHA (Computer-Aided Management of
Emergency Operations / Areal Location of Hazardous Atmospheres), developed by the
USEPA and the National Oceanic and Atmospheric Administration [33]. CAMEO is a suite
of software used for pre-planning and responding to chemical emergencies. ALOHA is a
component of CAMEO that is used for atmospheric dispersion modeling and estimation of
threat zones. ALOHA uses the following hierarchy for selection of the toxic LOC: 60-
minute AEGL > ERPG > TEEL > IDLH. A typical ALOHA plot is presented in Figure 1,
with the 3 threat zones presented as red (AEGL-3), orange (AEGL-2), and yellow (AEGL-1)
[34]; the threat zones are then used to develop emergency action plans and determine areas
of evacuation and/or sheltering.
ALOHA is designed to be easy to use and to produce results quickly enough to be useful for
responders in an emergency situation [35]. It is important to understand that the
atmospheric modeling provides only an estimate of the surrounding concentrations and
threat zones. Uncertainties in modeled concentrations may lead to under- or over-
estimations of threat zones and could potentially cause problems during an emergency (e.g.,
evacuation areas are too small or too large) [36]. Users of ALOHA, or any other atmospheric
dispersion modeling software, should be properly trained and have a thorough
understanding of the capabilities and limitations of the program.
Figure 1: An image of ALOHA toxic threat zones, indicating where

pollutant concentrations are higher or lower than the chosen levels of
concern (LOC). AEGLs are presented and the red (centre) threat zone is the
most hazardous (AEGL-3) [34]
Other software tools used for hazard analyses (or consequence analyses) include CAPARS
(Computer-Assisted Protective Action Recommendation System), the NARAC (National
Atmospheric Release Advisory Center) modeling system, EPIcode, PHAST (Process Hazard
Analysis Software Tool), and CASRAM (Chemical Accident Statistical Risk Assessment
Model) [37,38]. Consequence analysis tools found in the recent white literature include
TORCAT (TOxic Release Consequence Analysis Tool), a CFD FLACS-DDC
(Computational Fluid Dynamics FLame Acceleration Simulator - Damage Differential
Coupling) model, and a Risk Severity Index tool for industrial sites [39,40,41,42]. Further
evaluation of the various software tools used in emergency management was beyond the
scope of this review.
Sections 4.1 to 4.3 present specific accounts of real-world usage of AEGLs, ERPGs,
TEELs, and/or the PAC dataset as a whole. The lists are not exhaustive, but rather provide
several examples of the types of groups or agencies that utilize these emergency guidelines
and the situations in which they are used. Application and selection of emergency guideline
values tends to vary between agencies and industries, and usage of the guidelines often
differs from that of the DOE. For example, many agencies use only AEGLs and ERPGs
rather than the PAC dataset. Additionally, some agencies may use a different hierarchy for
selection of toxicological endpoint. For several of the examples presented, the referenced
documents provided very little detail on how and why the specific PAC values are used.
4.1 Agencies Utilizing Protective Action Criteria
4.1.1 Canada
Environment Canada makes use of AEGLs and ERPGs in their Environmental Emergency
(E2) Regulations. E2 regulations require "persons who own or manage specified toxic and
hazardous substances at or above the specified thresholds to provide required information
on the substance(s), their quantities and to prepare and implement environmental emergency
plans" [43]. Environment Canada utilizes an evaluation framework methodology to evaluate
the properties of chemicals that would be hazardous during an environmental emergency
and to calculate the specified thresholds [44]. For substances that are hazardous to human
health when inhaled, the specified threshold value is calculated using, in order of priority,
AEGL-2 (30 min), IDLH, or ERPG-2 values as the measure of toxicity. When neither of
these values is available, lethal concentration limits from animal studies (e.g., LC50, LCLO) are
used to estimate an IDLH.
AEGL and ERPG values were also used in the '2012 Emergency Response Guidebook',
published jointly by Transport Canada, the US Department of Transportation, and the
Secretariat of Communications and Transportation of Mexico [45]. The guidebook offers
general guidance for first responders (e.g., firefighters, police, and other emergency services
personnel) to an emergency transportation incident involving dangerous goods or hazardous
materials. The information provided in the guidebook assists first responders in identifying
the hazards of the material(s) involved in the incident, and protecting themselves and the
general public during the initial response phase. The guidebook includes tables of estimated
initial isolation and protective action distances for large and small spills of various hazardous
materials. The initial isolation zone is defined as the area surrounding the incident in which
persons may be exposed to dangerous (upwind) and life threatening (downwind)
concentrations of material. The protective action zone is defined as the area downwind from
the incident in which persons may become incapacitated and unable to take protective action
and/or incur serious or irreversible health effects. In determining the initial isolation and
protective action distances, the toxicological endpoints used, in order of priority, were
AEGL-2 and ERPG-2 values. When AEGL-2 or ERPG-2 values were not available, lethal
concentration limits derived from animal studies were used. For each chemical, thousands of
hypothetical releases were modeled under various meteorological and release conditions; the
90th percentile initial isolation and protective action distances for each chemical were
selected for the tables.
4.1.2 USA
A large number of agencies in the USA utilize AEGLs, ERPGs, TEELs, or PACs for
emergency planning and response. The National Oceanic and Atmospheric Administration
(Office of Response and Restoration) includes PACs as the toxic LOC for emergency
response and in their tools for hazard analysis [46]. The USEPA's Risk Management
Program uses ERPG-2 as the first choice for a toxic endpoint for hazardous substances in
offsite consequence analyses [47,48]. The toxic endpoint values are then used to estimate
consequence distances in worst-case scenario analyses.
The Interagency Modeling and Atmospheric Assessment Center (IMAAC) makes use of
PACs to determine threat zones during a chemical emergency [49]. The IMAAC consists of
representatives from 7 federal agencies (USEPA, DOE, National Oceanic and Atmospheric
Administration, Department of Homeland Security, Department of Defense, National
Aeronautics and Space Administration (NASA), and the Nuclear Regulatory Commission),
and is often called upon to assist local responders in large-scale chemical emergencies.
The Department of the Army and the Federal Emergency Management Agency adopted
AEGLs into their policy for the Chemical Stockpile Emergency Preparedness Program
(CSEPP) [50,51]. AEGLs are the toxicity criteria to be used in emergency planning and
response by the CSEPP community. Specifically, the guidelines are to be utilized in air
dispersion models to identify areas at risk from potential chemical warfare accidents. Other
national agencies and programs utilizing PACs include the DOE environmental restoration,
waste management, waste transport, and fixed facility programs, the Department of Defense
environmental restoration, waste management, and fixed facility programs, the ATSDR
health consultation and risk assessment programs, the American Chemistry Council
Chemtrec program, the Department of Transportation Emergency Response Guidebook
(see Transport Canada above), and OSHA and NIOSH regulations and guidelines for
workplace exposure [9]. For example, NIOSH utilizes AEGL-1 and AEGL-2 values in the
'Emergency Response Safety and Health Database' to identify the concentrations at which
first responders are required to use personal protective equipment [52].
PACs are also used by local and state governments. For example, the Virginia Department
of Environmental Quality uses PAC-1 values for assessments of the potential health impact
from air discharges related to soil remediation [53]. Additionally, the Texas Commission on
Environmental Quality uses AEGL-1 odour detection values in their guidelines for setting
odour-based Effects Screening Levels [54].
Use of PACs was found in documentation for emergency pre-planning in anticipation of a
chemical terrorist attack at the Los Angeles airport [55]. AEGL-1, and secondarily AEGL-2
or ERPGs, were used as the exposure guidance levels for the development of clearance goals
for airport remediation following a terrorist attack involving chemical warfare agents.
4.1.3 Worldwide
In Australia, accounts of AEGL and ERPG usage were found in state government
documents. In Queensland, AEGL-2 and ERPG-2 values are used as the threshold levels for
the 'dangerous dose to human health', which is not to be exceeded for foreseeable hazard
scenarios [56]. In Victoria, the document titled 'A Best Practice Approach to Shelter-in-Place
for Victoria' indicates that AEGLs and ERPGs are used by scientific and health
professionals during chemical emergencies to assist with the decision making process [57].
PACs are also used to some extent in Europe; for example, regulation documents indicated
that AEGLs and ERPGs are the toxic endpoints used in risk analyses for land-use planning
in the European Union [58] and Denmark [59]. In the United Kingdom, values for AEGLs
and ERPGs are included in the Incident Management documents for specific chemicals
[60,61]; however, no further details were found regarding how the guidelines are used.
In a survey evaluating risk assessment of chemical exposures in emergency response
situations across Europe, the most commonly used acute exposure reference values were, in
decreasing order, ERPGs, AEGLs, and IDLHs [62]. TEELs and European Acute Exposure
Threshold Levels (AETLs; analogous to AEGLs) were used less frequently. Typical uses of
the acute exposure reference values included land-use planning, emergency planning,
evacuation distance estimation, medical planning, and consequence analysis.
The Chemical Events Working Group of the Global Health Security Initiative published an
article indicating use of AEGL-3 values, and secondarily PAC-3 values, in their chemical risk
screening tool [63]. The tool is used to prioritize public health risk associated with the
accidental or deliberate release of chemicals at the local, regional, national, and international
levels.
Lastly, use of ERPG values was found in the Chemical Exposure Index (CEI) developed by
Dow Chemical [64,65]. The CEI is a method of rating the relative acute health hazard
potential of possible chemical release incidents. ERPG-1, ERPG-2, and ERPG-3 values are
used the measure of toxicity in the calculations of the CEI and hazard distances for potential
incidents.
4.2 Past Chemical Emergency Events

The following list presents examples of actual chemical emergency events where AEGLs,
ERPGs, TEELS, or the PAC dataset were used to identify threat zones and the potentially
affected population. Accounts of usage of these guidelines in actual emergency events were
difficult to find, likely due to limited published documentation of past chemical events. For
most incidents, very little information was found and it was not possible to assess the
suitability or effectiveness of the usage of PACs for the particular event.
Paulsboro, New Jersey, USA, 2012 [66]
Train derailment led to release of vinyl chloride. Interim AEGLs for vinyl chloride
were used to identify red (AEGL-3), orange (AEGL-2), and yellow (AEGL-1) threat
zones.
Kilauea, Hawaii, USA, 2008 [67]
Kilauea volcanic eruption led to release of sulfur dioxide. AEGL-1 and AEGL-2 (60-min)
were used as the acute health effect endpoints to identify threat zones and the number of
people potentially affected.
Port of Montreal, Quebec, Canada, 2007 [68]
Grounding of the Sichem Aneline tanker that was carrying 7700 m3 of benzene.
AEGL-2 and ERPG-2 were used to identify threat zones for several potential benzene
release scenarios.
Central Taiwan, 2007 [69]
Boiler explosion at a chemical plant resulting in the release of xylene, isopropanol,
phosphorus trichloride, and dimethyl formamide. On-site concentrations of
contaminants were compared to ERPGs to determine the appropriate emergency
action. Xylene and nitrogen dioxide were found to exceed the emission standards but
not the evacuation standards; thus, it was suggested that windows be closed in all
industrial park plants located downwind from the explosion site. Additionally, leakage
simulations of hydrogen chloride (product of phosphorus trichloride and water) were
performed using ALOHA, and the results were used to estimate the geographic areas
impacted by ERPG-1, ERPG-2, and ERPG-3 concentrations.
Graniteville, South Carolina, USA, 2005 [49]

Train accident leading to release of chlorine. ERPGs were used during emergency
response to determine red (ERPG-3), orange (ERPG-2), and yellow (ERPG-1) threat
zones. Field measurements of chlorine were found to show a strong agreement with
modeled concentrations. In follow-up studies of the incident, modeled chlorine
concentrations and associated AEGLs were compared to published epidemiologic data
of adverse health effects [70]. Modeled estimations of chlorine concentrations and
adverse outcomes were in general agreement with epidemiologic findings, confirming
the validity of the chlorine dispersion model and AEGL values for this scenario.
Contrarily, another report indicated that the use of ALOHA in this emergency lead to
an overestimation of plume speed and downwind concentration, which possibly
resulted in an over-prediction of the evacuation area [71].
Dalton, Georgia, USA, 2004 [72]
Leakage of allyl alcohol and allyl chloride during a runaway chemical reaction at MFG
Chemical Inc. In a follow-up investigation report, AEGL-1/ERPG-1 and AEGL-
2/ERPG-2 values were used to estimate threat zones and the number of potentially
affected people.
Cincinnati, Ohio, USA, 2004 [67]
Massive fire at Queen City Barrel chemical warehouse led to release of several
chemicals in smoke plume. ERPGs (and possibly other guidelines) were used to map
acute health impacts.
Table 5: Examples of protective action criteria (PACs) usage in

consequence analyses (white literature)
PAC Application Location Publication Reference
Date
PAC Consequence analysis for chemical leakage of toxic dust Greece 2011 [74]
particles from an abandoned mining and metallurgical
facility
Consequence analysis at DOE hazard facilities (Los USA 2006 [75]
Alamos National Laboratory, Lawrence Livermore
National Laboratory, Oak Ridge-Y12, Pantex, Rocky
Flats, and West Valley)
AEGL Consequence analysis for leakage simulations of Texas, USA 2012 [76]
liquefied ammonia
Consequence analysis for leakage simulations of chlorine Missouri and 2012 [71]
from a ballistic attack on a chlorine-carrying railway Illinois, USA
tanker
Consequence analysis and assessment of human China 2010 [77]
vulnerability to leakage simulations of chlorine from a
chemical industrial park
Consequence analysis for leakage simulations of Malaysia 2010 [41]
ammonia from an ammonia production plant
Consequence analysis and determining toxic effect India 2011 [78]
distances for potential accidents related to hazardous
materials transport (ammonia, 1,3-butadiene, ethylene
oxide, liquefied petroleum gas, propylene)
ERPG Consequence analysis and determining protective action Illinois, USA 2007 [79]
PAC Application Location Publication Reference

Date
distances for potential accidents related to hazardous
materials transport
Consequence analysis for leakage simulations of Taiwan 2012 [80]
chlorine, epichlorohydrin, and phosgene from chemical
production facilities
Consequence analysis and determination of toxic effect Slovenia 2007 [81]
distances for leakage simulation of chlorine
Consequence analysis for leakage simulations of allyl New Jersey, 2008 [82]
alcohol, boron trifluoride, and methyl chloride in USA
various accident scenarios
ERPG, Consequence analysis for leakage simulations of sulfuric Mexico 2012 [83]
TEEL acid, sulfur dioxide, sulfur trioxide, iodine, and hydriodic
acid from a hydrogen production plant
TEEL Consequence analysis for leakage simulations of Italy 2010 [84]
propane during a potential transportation accident
Table 6: Examples of protective action criteria (PACs) usage in

consequence analyses in environmental impact assessments (grey
literature)
PAC Application Agency Publication Reference
Date
PAC In an environmental impact statement for a deep Ontario 2013 [85]
geologic repository for the long-term management of Power
low and intermediate level waste, it was indicated thatGeneration
chemicals released during credible accident scenarios (Ontario,
would be less than PAC-1 Canada)
AEGL In an environmental impact statement for a carbon US 2013 [86]
capture and sequestration project, AEGLs (3 levels) Department
were used to determine threat zones (distances and of Energy
population densities) for various chemical leakage (Louisiana,
simulations USA)
In an assessment of health impacts related ICF 2012 [87]
to accidental releases from hazardous waste facilities, the
International
consequence analysis indicated that concentrations (at (for USEPA)
nearby receptors) resulting from worst-case spill (California,
scenarios would be less than AEGL levels USA)
In an environmental impact assessment for a national US 2012 [88]
petroleum reserve, it was determined that hazardous airDepartment
pollutant emissions would not exceed AEGL-1 levels of the Interior
Bureau of
Land
Management
(Alaska, USA)
ERPG In an environmental and social impact assessment for a Nghi Son 2011 [89]
petrochemical refinery, ERPGs (3 levels) were used for Refinery and
review of hazard consequences and hazard distances for Petrochemica
credible chemical release scenarios l LLC
PAC Application Agency Publication Reference

Date
(Vietnam)
In a hazard assessment report for oil and gas platforms US 2009 [90]
and pipelines, ERPG-3 levels for hydrogen sulfide were Department
used as a level of concern in the consequence analysis of the
for potential release scenarios Interior
Minerals
Management
Service
(California,
USA)
In an environmental impact report for the development Venoco Inc 2008 [91]
of new oil and gas reserves at a processing facility, it was (California,
indicated that hydrogen sulfide concentrations are not to USA)
exceed the ERPG-2 level at any location within the
facility
In a hazard and risk assessment for a proposed Dyno Nobel 2006 [92]
ammonium nitrate plant, ERPG-2 and ERPG-3 values Asia Pacific
were used in consequence modeling for toxic release LTD
scenarios (Australia)
ERPG, In a technical basis document for a nuclear storage CH2M HILL 2005 [93]
TEEL facility, ERPG-1/TEEL-1 and ERPG-2/TEEL-2 values Hanford
were used to assess severity of potential accident Group, Inc
scenarios for above-ground tanks. Results were (Washington,
combined with a frequency/probability analysis to USA)
determine risk categories for various accident scenarios
5. Advantages and Limitations of the Protective

Action Criteria
Advantages of PACs include:
• The PAC dataset provides emergency inhalation exposure guidelines for ~3400
substances to assist in the management of chemical emergencies.
• AEGL and ERPG development involves an analysis of all available toxicological
data and a rigorous review process. AEGLs and ERPGs are peer-reviewed.
• Intended to be protective for most of the general public, including susceptible
populations (identified as infants, children, the elderly, persons with asthma, and
those with other illnesses).
• PACs have been incorporated into several atmospheric dispersion modeling
programs.
• TEEL values can be developed relatively quickly as they are derived using existing
exposure guidelines or toxicity data. In the absence of AEGLs or ERPGs, TEELs
can be a useful source of information.
Limitations for PACs include:

• AEGLs and ERPGs are available for a relatively small number of chemicals (~270
AEGLs (final, interim, and proposed) and ~145 ERPGs, compared to over 3000
TEELs). The extensive review process involved in AEGL and ERPG derivation
requires a significant amount of time and resources.
• TEEL values are not peer-reviewed and are considered less reliable than AEGLs and
ERPGs.
• For chemicals with both AEGLs and ERPGs, the guideline values for a specific tier
may vary considerably. For example, for hydrogen sulfide, the values for ERPG-1
(0.1 ppm) and AEGL-1 (60-min; 0.51 ppm) differ by five-fold (Appendix A). Oberg
et al. (2010) evaluated discrepancies between AEGL and ERPG values; of 88
substances that had both AEGLs and ERPGs, 34 substances (39%) had values that
diverged by more than three-fold [94]. The main reasons for divergence included
selection of critical effect, selection of critical studies, definition of health effect tier
(particularly for AEGL-1 and ERPG-1), interpretation of data, and use of different
modifying factors. These discrepancies may lead to problems with interpretation and
communication in risk management, particularly during large-scale releases with
multiple parties involved (e.g., one agency uses AEGL values and another agency
uses ERPG values).
• When using the consolidated PAC dataset, only one exposure period is available (1
hour). This can lead to some confusion when actual exposure times are shorter or
longer. This is particularly important for chemicals that do not have an AEGL (with
a range of exposure durations) to refer to. In a survey of European professionals
involved in chemical risk assessment and emergency planning, use of acute exposure
reference values was considered difficult by 35% of respondents [62]. The problems
associated with use were mainly related to the availability of only a single exposure
period, particularly for ERPGs.
• Neither AEGLs, ERPGs, nor TEELs are designed to be protective of hypersensitive
individuals (those whose reactions to chemical exposure are unique and idiosyncratic
and lie outside the range of distributions expected for the general population
including susceptible individuals) [1,9].
• AEGLs have been criticized for the methods in which individuals with asthma are
considered in guideline development; Johansson et al. (2012) found that 70% of
AEGL technical support documents lack explicit comments or statements relating to
individuals with asthma [95].
• Uncertainties in atmospheric modeling may lead to under- or over-estimations of
threat zones and potentially cause problems during an emergency (e.g., evacuation
areas are too small or too large) [36]. For example, ALOHA results can be unreliable
under certain meteorological conditions (e.g., very low wind speeds) and may not be
appropriate for certain emergency scenarios [35]. Users of ALOHA, or any other
atmospheric dispersion modeling software, should be properly trained and have a
thorough understanding of the capabilities and limitations of the program.
• PACs are not directly applicable to releases of chemical mixtures, as the potential
additive, synergistic, or antagonistic effects that may result from exposures to
multiple chemicals are not accounted for. Chemicals in combination may behave
differently than when alone, and predicting the toxic potential of a mixture is often
very difficult. A chemical mixture methodology (CMM) has been developed by
SCAPA for estimating the potential health impacts of exposures involving multiple
chemicals [96,97,98]. This method utilizes the concentration of each chemical, the
PAC value, and health code numbers that identify the target organs of the chemicals
to estimate the potential health impact of a mixture at a given location. A user guide
and CMM workbook (for mixtures of up to 30 chemicals) are available from the
DOE-sponsored Emergency Management Issues Special Interest Group [99]. Yu et
al. (2010) indicate that the CMM is used by the DOE, its contractors and other
private and public sector organizations for emergency response and safety planning
[97]. However, specific references to the usage of the CMM for chemical
emergencies were difficult to find and it is not known how often this method is used.
Additional notes regarding PACs:

• PACs are applicable only to short-term inhalation exposures of 1 hour (or up to 8
hours for chemicals with AEGLs); they are not intended for other routes of
exposure (e.g., drinking water, soil) or longer term exposures. For emergency
exposures lasting 24 hours to 2 years, a separate set of emergency guidelines, titled
provisional advisory levels (PALs), are available for air and drinking water.
• PACs are used to assess the potential severity of an emergency event, and should not
be used as safe limits for repeated exposures, as delineators between safe and unsafe
exposure levels, as the basis levels for quantitative risk assessment, or to estimate
expected injuries or casualties [100,101].
6. Summary
PACs are emergency exposure guidelines that are used before or during an unplanned release
of a hazardous chemical in the air. The guidelines are intended to protect the general public,
including susceptible individuals, from health effects resulting from a rare short-term
exposure to a chemical. PACs can be used prior to emergencies to estimate the toxic severity
of potential accident scenarios (hazard analysis or consequence analysis), or during chemical
emergencies to identify threat zones and the populations that may be at risk.
PACs are a consolidated list of 3 types of emergency exposure guidelines: AEGLs, ERPGs,
and TEELs. AEGLs and ERPGs are the preferred emergency guidelines, in that order, but
are only available for a limited number of chemicals. For chemicals without AEGLs or
ERPGs, TEELs are used until AEGLs or ERPGs are developed.
There are 3 health effect levels for PACs: (1) mild, transient effects; (2) irreversible or serious
effects that could impair the ability to take protective action; and (3) life-threatening effects.
PACs are based on a 60-minute exposure duration, though AEGLs also include guidelines
for durations of 10 minutes, 30 minutes, 4 hours, and 8 hours.
The main difference between the 3 emergency guidelines is the methods in which they are
derived. AEGL and ERPG development is a thorough and rigorous process involving
review of all primary source data. Because of this time-consuming process, AEGLs and
ERPGs have only been developed for ~270 (final, interim, and proposed) and ~145
substances, respectively. TEEL values, on the other hand, are based on secondary sources of
data (existing exposure limits) and require less time to develop. Thus, TEELs are available
for a large number of substances (> 3000), though are somewhat less reliable.
AEGLs, ERPGs, TEELs, and PACs are used by several reputable governing agencies in
Canada, the USA, and abroad. Application and selection of guideline values tends to vary
between agencies and industries, and usage of the guidelines often differs from that of the
DOE. For example, many agencies use only AEGLs and ERPGs rather than the PAC
dataset. Additionally, there were few references to the usage of TEEL values. This is likely
because AEGLs and ERPGs are available for commonly used chemicals that are more likely
to be involved in a chemical accident, and AEGLs and ERPGs are considered more reliable
and scientifically sound than TEELs.
In summary, PACs are an important source of information for emergency planning and
emergency response, providing toxic endpoint values that can be used to determine threat
zones and estimate potential health impacts on a surrounding population. AEGLs and
ERPGs are the preferred guidelines for use prior to or during a chemical emergency.
However, TEELs can also be valuable when a chemical emergency occurs involving a
substance with no AEGL or ERPG available.
7. References
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AEGLs, ERPGs, & TEELs. Retrieved May 20, 2014 from
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95.
Appendix: Summary of Guidelines for H2S

To illustrate the variation in guidance values for a specific chemical, a summary of guideline
levels for hydrogen sulfide (H2S) is presented below (modified from [18]).
Table 7: Summary of H2S guideline values from various jurisdictions

Standard or Guideline Value Source
(ppm)
USEPA RfC 0.001 www.epa.gov/iris
Alberta AAQO (24-hr average) 0.003 esrd.alberta.ca/air/objectives-directives-policies-and-
standards/documents/5726.pdf
OEHHA CA-REL (Chronic; 0.008 oehha.ca.gov/air/allrels.html
Annual)
Approximate Odour Threshold 0.01 www.epa.gov/oppt/aegl/pubs/chemlist.htm
Alberta AAQO (1-hr average) 0.01 esrd.alberta.ca/air/objectives-directives-policies-and-

standards/documents/5726.pdf
ATSDR Intermediate MRL 0.02 www.atsdr.cdc.gov/mrls/mrllist.asp
OEHHA CA-REL (Acute; 1-hr) 0.03 oehha.ca.gov/air/allrels.html
ATSDR Acute MRL 0.07 www.atsdr.cdc.gov/mrls/mrllist.asp
ERPG-1 0.1 toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB
AEGL-1 8-hr 0.33 www.epa.gov/oppt/aegl/pubs/chemlist.htm
AEGL-1 4-hr 0.36 www.epa.gov/oppt/aegl/pubs/chemlist.htm
PAC-1 (AEGL-1 1-hr) 0.51 www.atlintl.com/doe/teels/teel/Table2.pdf
AEGL-1 60-min 0.51 www.epa.gov/oppt/aegl/pubs/chemlist.htm
PAL-1 30-day and 90-day 0.85 www.ncbi.nlm.nih.gov/pubmed/19827914
ACGIH TLV-TWA 1 toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB
NAS CEGL 90-day 1 www.nap.edu/openbook.php?record_id=12741&pa

ge=129
PAL-1 24-hr 1.2 www.ncbi.nlm.nih.gov/pubmed/19827914
Human NOAEL 2 www.atsdr.cdc.gov/toxprofiles/index.asp
Asthmatic LOAEL 2 www.atsdr.cdc.gov/toxprofiles/index.asp
PAL-2 30-day and 90-day 3 www.ncbi.nlm.nih.gov/pubmed/19827914
ACGIH TLV-STEL 5 toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB
MAK (Germany) 5 onlinelibrary.wiley.com/doi/10.1002/9783527666034.oth0

1/pdf
Standard or Guideline Value Source

(ppm)
PAL-2 24-hr 7 www.ncbi.nlm.nih.gov/pubmed/19827914
NIOSH REL (ceiling; 10-min) 10 www.cdc.gov/niosh/npg/default.html
NAS EEGL 24-hr 10 www.nap.edu/openbook.php?record_id=12741&pa

ge=129
AEGL-2 8-hr 17 www.epa.gov/oppt/aegl/pubs/chemlist.htm
OSHA PEL (ceiling; 10-min) 20 www.cdc.gov/niosh/npg/default.html
PAC-2 (AEGL-2 1-hr) 27 www.atlintl.com/doe/teels/teel/Table2.pdf
AEGL-2 60-min 27 www.epa.gov/oppt/aegl/pubs/chemlist.htm
PAL-3 24-hr 27 www.ncbi.nlm.nih.gov/pubmed/19827914
ERPG-2 30 toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB
PAC-3 (AEGL-3 1-hr) 50 www.atlintl.com/doe/teels/teel/Table2.pdf

Protective Action Criteria A Review

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Protective Action Criteria A Review

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Protective Action Criteria

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For more information, please contact:

Oceanic and Atmospheric Administration, US Department of Transportation, US

programs should be properly trained and have a thorough understanding of the

Adrienne LeBlanc Environmental Health Consultant

With contributions from:

Merry Turtiak Alberta Health

Special thanks to our peer-reviewers for their valuable editorial comments:

Jennifer Graydon Alberta Health

TDLO: Toxic dose - lowest

2. Background Information on the Protective

2.1 Acute Exposure Guideline Levels (AEGLs)

2.1.1 Definitions of AEGLs

AEGL-3: the airborne concentration of a substance above which it is predicted

2.1.2 Derivation of AEGLs

Table 1: Criteria used for selection of health endpoints for derivation

2.2 Emergency Response Planning Guidelines (ERPGs)

2.2.1 Definitions of ERPGs

2.2.2 Derivation of ERPGs

2.3 Temporary Emergency Exposure Limits (TEELs)

2.3.1 Definitions of TEELs

notable discomfort, irritation, or certain asymptomatic nonsensory effects.

2.3.2 Derivation of TEELs

adjustments for animal-human extrapolations, time extrapolations, and route of exposure

Table 2: Hierarchy of selection of toxicity parameters used for TEEL

TEEL Hierarchy of Toxicity Parameters (in order of Source of Data

2.4 Comparison of AEGLs, ERPGs, and TEELs

Table 3: Comparison of AEGLs, ERPGs, and TEELs (modified from

3. Comparisons with Other Air Guideline Levels

4. Usage of Protective Action Criteria

Table 4: Comparison of various air guideline levels

Guideline Definition Exposure Exposure Developed

Guideline Definition Exposure Exposure Developed

When responding to or planning for a chemical emergency, field measurements and/or

Figure 1: An image of ALOHA toxic threat zones, indicating where

4.1 Agencies Utilizing Protective Action Criteria

4.2 Past Chemical Emergency Events

Graniteville, South Carolina, USA, 2005 [49]

Table 5: Examples of protective action criteria (PACs) usage in

PAC Application Location Publication Reference

Table 6: Examples of protective action criteria (PACs) usage in

PAC Application Agency Publication Reference

5. Advantages and Limitations of the Protective

Limitations for PACs include:

Additional notes regarding PACs:

Volume 6. Retrieved May 15, 2014 from www.blm.gov/epl-front-

Appendix: Summary of Guidelines for H2S

Table 7: Summary of H2S guideline values from various jurisdictions

Alberta AAQO (1-hr average) 0.01 esrd.alberta.ca/air/objectives-directives-policies-and-

OEHHA CA-REL (Acute; 1-hr) 0.03 oehha.ca.gov/air/allrels.html

ATSDR Acute MRL 0.07 www.atsdr.cdc.gov/mrls/mrllist.asp

ERPG-1 0.1 toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB

AEGL-1 8-hr 0.33 www.epa.gov/oppt/aegl/pubs/chemlist.htm

AEGL-1 4-hr 0.36 www.epa.gov/oppt/aegl/pubs/chemlist.htm

PAC-1 (AEGL-1 1-hr) 0.51 www.atlintl.com/doe/teels/teel/Table2.pdf

AEGL-1 60-min 0.51 www.epa.gov/oppt/aegl/pubs/chemlist.htm

AEGL-1 30-min 0.6 www.epa.gov/oppt/aegl/pubs/chemlist.htm