Toxicology Update Tiffany Bredfeldt, Ph.D. Toxicology Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2015 Updates • • • • New Odor White Paper Updated Odor Values Reminder to Use New ESL Forms Database in Progress Why Do We Regulate Odors? • Odor - leading cause of citizen complaints • Required by the Texas Clean Air Act • What is the role of the odor-based ESL? – Prevent odor nuisance conditions – Not necessarily odor detection New Odor White Paper • Approach to odor ESL derivation has changed • New approach uses a weight of evidence evaluation • Visit the Toxicology website for more information Odor White Paper: Why Change? • Odor data is highly variable • The reason for the variance is unclear • The purpose of an odor-based ESL is to prevent nuisance • The goal is to produce a list of odor ESLs consistent in the manner in which they are derived Odor: Previous Approaches • Collect odor thresholds: – Odor detection threshold - concentration at which a certain percent of a panel of humans detects odor – Odor recognition threshold - concentration at which a chemical is recognized specifically – The 50% odor detection threshold is typically used Odor: Previous Approaches • For chemicals with reported thresholds, the 50% odor detection threshold was used • If more than one OD50 was available, a geometric average was taken • If data was considered of lower quality, the lowest OD50 was taken • For chemicals without odor detection thresholds, generic odor values were derived based on structure-activity relationships or chemical class Previous Approaches: Pitfalls • Odor threshold data are highly variable • Newer methodologies may be very sensitive and may result in bias • If older values have not resulted in an odor complaint, should we change the value to newer data? Odor: Updated Approaches • Process is similar • Steps: – Identify odor character – Is the chemical potentially malodorous? – Search for available odor threshold data • Agency records may guide the decisions regarding the odor ESL used • Not all chemicals will have odor ESLs • The focus is upon chemicals that could cause nuisance Not all chemicals smell bad Isoamyl acetate Limonene Cis-rose oxide Beta-damascenone Beta-ionone Ocimenol Cinnamyl alcohol Ethyl-2-methoxybenzoate Methyl salicylate Some chemicals smell bad Trimethylamine Ammonia Hydrogen Sulfide Methane 1,5-Pentanediamine 1,4-Butanediamine 2-Butene-1-thiol 3-Methyl-1-butanethiol Odor: Updated Approaches • If there is evidence that a chemical may cause odor nuisance but only at high concentrations, higher thresholds may be used • Examples: – Acetaldehyde – Propionaldehyde • Odor recognition threshold may be used Example: Propionaldehyde • Previous value (OD50): 22 µg/m3 • Odor is described as fruity at lower concentrations • Upon evaluation of available monitoring data, this value has been detected at sites where the odor was described as sweet by field investigators • New value (OR50): 95 µg/m3 Odor: Updated Approaches • When selecting odor-based values: – Consider odor character – Determine odor if odor character is ubiquitous or dependent on concentration – Identify available odor thresholds – Research past values used (if any) and whether any odor complaints are associated with this chemical – Select odor threshold Odor: Other Changes • No generic odor values will be used anymore (e.g., amines or carboxylic acids odor value) • Instead, when odor values are not available, ESLs will be surrogated to chemicals with similar structure • Values for chemicals where odor is described as mild or pleasant will not be derived • In those cases, health values will be used • All odor ESLs were reviewed at the same time • Consistent application of new guidance Odor Summary • Some approaches to how we derive odorbased ESLs have changed • We will still derive odor ESLs as needed for chemicals anticipated to be malodorous • Detection or recognition thresholds may be used as the basis • New odor values may be seen in the updated database • And on our website Additional Updates • ESL Documentation • ESL Database Project Internet ESL Documentation • New form to fill out for ESL requests • The paperwork processed during ESL derivation has changed within the Toxicology Division • That means that ESL derivations may take a bit longer due to the way records are generated and placed into a format that will be used for the database • Expect a longer turnover time ESL Documentation • Make sure that you fill out the ESL request form • When consultants or companies ask for an ESL for a specific chemical: – Check current ESL list – Fill out ESL request form – Get additional information (i.e., MSDS, physical chemical properties, etc.) ESL Documentation • Documentation may have slowed turn around time • We are releasing a new ESL list this fall • Please remember to check our website for ESLs • New list will be publicized via the Toxicology Announcements (e-mail) Database • The ESL database is still in the process of being generated • Some issues with getting it coded • When complete, it should run through the public database TAMIS • In PROGRESS! • Keep up with the Toxicology Division Announcements online Thank you for your attention Tiffany Bredfeldt tiffany.bredfeldt@tceq.texas.gov 512-239-1799