1
Gilman,
Paul,
and
Susan
Hazen,
2004.
Status
of
EPA's
Dioxin
Reassessment,
Note
to
Tom
Gibson
and
Rich
McKowen,
February
17,
2004.

2
U.
S.
EPA,
1985.
Health
Assessment
Document
for
Polychlorinated
Dibenzo­
p­
Dioxins.
EPA/
600/
8­
84/
014F.
Final
Report.
Office
of
Health
and
Environmental
Assessment.
Washington,
DC.
September,
1985.
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
SOLID
WASTE
AND
EMERGENCY
RESPONSE
DATE:
March
31,
2004
MEMORANDUM
SUBJECT:
Assessment
of
Human
Health
Benefits
Associated
with
Reduced
Exposure
to
Dioxin:
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Proposed
Standards
for
Hazardous
Air
Pollutants
for
Hazardous
Waste
Combustors
(
Phase
I
Final
Replacement
Standards
and
Phase
II)

FROM:
James
R.
Berlow,
Director
Hazardous
Waste
minimization
and
Management
Division
Office
of
Solid
Waste
TO:
Docket
ID
Number:
OAR­
2004­
0022
MACT
Rule
for
Hazardous
Waste
The
Office
of
Solid
Waste
assessed
human
health
benefits
anticipated
from
the
reduction
in
dioxin
exposure
in
response
to
the
proposed
Hazardous
Waste
Combustor
MACT
Rule
(
Phase
I
Final
Replacement
Standards
and
Phase
II).
The
methodology
applied
in
this
benefits
analysis
is
consistent
with
current
Agency
policy
on
dioxin
toxicity,
as
summarized
in
Status
of
EPA's
Dioxin
Reassessment,
February
17,
20041.
This
policy
indicates
that
the
dioxin
cancer
risk
slope
factor
of
1.56
x
105
[
mg/
kg/
day]­
1,
as
established
in
the
1985
Health
Assessment
Document
for
Polychlorinated
Dibenzo­
p­
Dioxins2,
is
the
appropriate
dioxin
toxicity
factor
to
use
as
a
rationale
for
regulatory
or
other
policy
actions.
3
U.
S.
EPA.
Exposure
and
Human
Health
Reassessment
of
2,3,7,8­
Tetrachloridobenzo­
p­
Dioxin
(
TCDD)
and
Related
Compounds:
Draft
Final
Rule,
National
Center
for
Environmental
Assessment,
September
2000.
However,
Agency
policy,
as
verified
by
senior
management,
further
allows
for
the
use
of
alternative
slope
factors
in
the
development
of
quantified
sensitivity
analyses.
Alternative
slope
factors
are
discussed
in
the
Agency's
draft
reassessment
document3.
Evidence
compiled
from
this
document
indicates
that
the
carcinogenic
effects
of
dioxin/
furans
may
be
as
much
as
six
times
as
great
as
believed
in
1985,
reflecting
an
upper
bound
cancer
risk
slope
factor
of
1
x
106
[
mg/
kg/
day]­
1
for
some
individuals.
Risks
could
also
be
as
low
as
zero
for
some
individuals.
