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Review of EPA's Updated Problem Formulation and Protocol for the Inorganic Arsenic IRIS Assessment (2019) / Chapter Skim
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Appendix A: Dissenting Statement and Rebuttal
Pages 12-14

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From page 12...
... My position regarding the need to use MOA data is consistent with the National Research Council's 2013 report entitled "Critical Aspects of EPA's IRIS Assessment of Inorganic Arsenic." The Sum mary, top of p. 6, states that, "Mode-of-action analyses should be used to inform dose–response modeling with respect to the shape of the curve, particularly in the low dose region, and the under standing of interhuman variability." Additionally, the Summary of the Report's 6-page Mode of Action Section, p.
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From page 13...
... In the opinion of the committee, this Bayesian technique provides an appropriate means of determining the shape of the doseresponse curve using actual data from a body of evidence that includes low-dose exposures within the observed range of human exposures. Additionally, the committee has recommended several types of sensitivity analyses, including the removal of the high dose range or studies with only high doses, to evaluate their influence on the shape of the dose-response curve, which directly addresses one of Dr.
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From page 14...
... Wash ington, DC: The National Academies Press. NRC (National Research Council)
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  • threshold approach
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  • moa analyses
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  • data throughout
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