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Request for Relevant Information on a Chemical Being Considered for Listing by the Authoritative Bodies Mechanism: Emissions from Combustion of Coal

The California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA) is requesting information as to whether the chemical in the table below meets the criteria for listing as known to the State to cause cancer under the Safe Drinking Water and Toxic Enforcement Act of 1986.1 This action is being proposed under the authoritative bodies listing mechanism.2

Chemical Appearing to Meet Criteria for Listing as Known to Cause Cancer

Chemical

Reference

Occurrence and Uses

Emissions from combustion of coal

IARC (2010)

Residential and industrial facility combustion of coal fuel

Background on listing via the authoritative bodies mechanism: A chemical must be listed under the Proposition 65 regulations when two conditions are met:

  1. An authoritative body formally identifies the chemical as causing cancer (Section 25306(d)3).
  2. The evidence considered by the authoritative body meets the sufficiency criteria contained in the regulations (Section 25306(e)).

However, the chemical is not listed if scientifically valid data which were not considered by the authoritative body clearly establish that the sufficiency of evidence criteria were not met (Section 25306(f)).

The International Agency for Research on Cancer (IARC) is designated as authoritative for the identification of chemicals as causing cancer (Section 25306(m)).
OEHHA is the lead agency for Proposition 65 implementation4. After an authoritative body has made a determination about a chemical, OEHHA evaluates whether listing under Proposition 65 is required using the criteria contained in the regulations.

OEHHA’s determination: The chemical in the table above appears to meet the criteria for listing as known to the State to cause cancer under Proposition 65, based on findings of the IARC (2010).

Formal identification and sufficiency of evidence for emissions from combustion of coal: In 2010, IARC published Volume 95 in the series IARC Monographs on the Evaluation of Carcinogenic Risks to Humans, entitled Household Use of Solid Fuels and High-temperature Frying (IARC, 2010). This report appears to satisfy the formal identification and sufficiency of evidence criteria in the Proposition 65 regulations for emissions from combustion of coal.

IARC concluded, “There is sufficient evidence in experimental animals for the carcinogenicity of emissions from combustion of coal.” OEHHA is relying on IARC’s discussion of data and conclusions in the report that emissions from combustion of coal cause cancer. Evidence described in the report includes studies showing that emissions from combustion of coal increase the incidences of malignant lung tumors in two studies in Kumming mice (squamous-cell carcinomas, adenosquamous carcinomas and adenocarcinomas in the study by Liang et al., 1988, and adenocarcinomas in the study by Lin et al., 1995) and one study in Wistar rats (squamous-cell carcinomas in the study by Liang et al., 1988).

Thus, IARC (2010) has found that emissions from combustion of coal cause increased incidence of malignant lung tumors in mice and rats.

Request for relevant information: OEHHA is requesting comments as to whether emissions from combustion of coal meets the criteria set forth in the Proposition 65 regulations for authoritative bodies listings.

After reviewing all comments received, OEHHA will determine whether the identified chemical meets the regulatory criteria for administrative listing. If the chemical is determined to meet the listing criteria, OEHHA will proceed with the formal listing process by publishing a Notice of Intent to List.

In order to be considered, OEHHA must receive comments by 5:00 p.m. on Tuesday May 14, 2013. We encourage you to submit comments in electronic form, rather than in paper form. Comments transmitted by e-mail should be addressed to P65Public.Comments@oehha.ca.gov with “DCI - emissions from combustion of coal” in the subject line. Comments submitted in paper form may be mailed, faxed, or delivered in person to the addresses below:

Mailing Address:
Office of Environmental Health Hazard Assessment
P.O. Box 4010, MS-19B
Sacramento, California 95812-4010
Fax: (916) 324-6511
Street Address: 1001 I Street
Sacramento, California 95814

Comments received during the public comment period will be posted on the OEHHA web site after the close of the comment period.

Optional public forum: Upon request, OEHHA will schedule an informal public forum to provide individuals an opportunity to present oral comments on the possible listing of this chemical. At the forum, the public may discuss the scientific data and other relevant information related to whether this chemical meets the criteria for listing in the regulations.

The request for a public forum must be submitted in writing to the Proposition 65 Office of OEHHA via email at sam.delson@oehha.ca.gov or to the attention of the Proposition 65 Office at the address listed above no later than Friday, April 12, 2013. If a public forum is requested, a notice will be posted on the OEHHA web site at least ten days before the forum date. The notice will provide the date, time and location of the forum. Notices will also be sent to those individuals requesting such notification.

If you have any questions, please contact Sam Delson at sam.delson@oehha.ca.gov or (916) 445‑6900.

Link to Public Comments

Comment period closed May 14, 2013. No comments received.

Footnotes and References

International Agency for Research on Cancer (IARC, 2010). IARC Monographs on the Evaluation of Carcinogenic Risks to Humans, Volume 95, Household Use of Solid Fuels and High-temperature Frying, IARC, World Health Organization, Lyon, France.

Liang CK, Quan NY, Cao SR et al. (1988). Natural inhalation exposure to coal smoke and wood smoke induces lung cancer in mice and rats. Biomed Environ Sci 1:42-50. PMID: 3268107

Lin C, Dai X, Sun X (1995). [Expression of oncogene and anti-oncogene in mouse lung cancer induced by coal-burning smoke]. Zhonghua Zhong Liu Za Zhi 17:432-434. PMID: 8697995.

 

1 Commonly known as Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986 is codified in Health and Safety Code section 25249.5 et seq.

2 See Health and Safety Code section 25249.8(b) and Title 27, Cal. Code of Regs., section 25306.

3 All referenced sections are from Title 27 of the California Code of Regulations.

4 Health and Safety Code section 25249.12 and Title 27, Cal. Code of Regs., section 25102(o).