1
Chromium
VI
Charge
to
the
HSRB
Chromium
VI
Charge
to
the
HSRB
Hexavalent
chromium
is
a
component
of
a
pesticide
product
intended
to
be
used
as
a
wood
preservative.
Members
of
the
general
public
may
experience
dermal
exposure
to
residues
of
hexavalent
chromium
remaining
on
wood
treated
with
a
wood
preservative.

Because
chromium
has
caused
allergic
contact
dermatitis
(
ACD)
in
occupational
settings,
EPA
has
determined
that
it
should
assess
the
potential
for
ACD
in
the
general
public
resulting
from
the
use
of
wood
preservatives
containing
chromium.
2
Chromium
VI
Charge
to
the
HSRB
Chromium
VI
Charge
to
the
HSRB
1.
Scientific
considerations
EPA
has
identified
a
study
performed
with
subjects
who
had
documented
sensitivity
to
chromium
(
Nethercott,
et
al.,
1994).
The
study
was
conducted
to
identify
a
level
of
exposure
to
chromium
below
which
dermal
exposure
did
not
appear
to
elicit
an
ACD
response.
Regarding
the
Nethercott
human
study,
the
Agency
has
concluded
that
the
study
contains
information
sufficient
for
assessing
human
risk
resulting
from
potential
dermal
exposure.

Please
comment
on
whether
the
Nethercott
study
is
sufficiently
sound,
from
a
scientific
perspective,
to
be
used
to
estimate
a
safe
level
of
dermal
exposure
to
hexavalent
chromium.
3
Chromium
VI
Charge
to
the
HSRB
Chromium
VI
Charge
to
the
HSRB
2.
Ethical
considerations
The
Agency
requests
that
the
Board
provide
comment
on
the
following:

a.
Is
there
clear
and
convincing
evidence
that
the
conduct
of
the
Nethercott
study
was
fundamentally
unethical?

b.
Is
there
clear
and
convincing
evidence
that
the
conduct
of
the
study
was
significantly
deficient
relative
to
the
ethical
standards
prevailing
at
the
time
the
research
was
conducted?
