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Application for the Reassessment of a Hazardous Substance under ...

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The APVMA (2008a) summarised:―Numerous in vitro and in vivo experiments have tested <strong>the</strong> genotoxic potential <strong>of</strong>dichlorvos, with <strong>the</strong> majority <strong>of</strong> data generated between 1972 and 1990 andpublished in <strong>the</strong> open scientific literature. In <strong>the</strong> current submission, sevenunpublished genotoxicity studies were evaluated, which showed that dichlorvoswas genotoxic in vitro but not in vivo. These findings are consistent with <strong>the</strong>extensive genotoxicity database <strong>for</strong> dichlorvos.―Dichlorvos is mutagenic and DNA-reactive in bacteria and o<strong>the</strong>r microorganismsin vitro, in both <strong>the</strong> presence and absence <strong>of</strong> exogenous metabolic activation(although effects were commonly reduced in <strong>the</strong> presence <strong>of</strong> exogenous metabolicactivation). Dichlorvos is also mutagenic and clastogenic in a range <strong>of</strong>mammalian cells exposed in vitro, including induction <strong>of</strong> UDS but notchromosomal aberrations or SCE in cultured human cells. In contrast, <strong>the</strong> majority<strong>of</strong> in vivo studies, including tests <strong>for</strong> induction <strong>of</strong> UDS, SCE, micronucleus<strong>for</strong>mation, chromosomal aberrations and dominant lethal mutations, have yieldednegative results. These negative in vivo genotoxicity results can be explained by<strong>the</strong> rapid metabolism and inactivation <strong>of</strong> dichlorvos, which appears to preventsystemic exposure to intact dichlorvos at concentrations likely to lead to directmolecular interactions.―Tungul et al. (1991) described micronucleus <strong>for</strong>mation in mouse epidermalkeratinocytes after direct application <strong>of</strong> dichlorvos to <strong>the</strong> skin, confirming thatdichlorvos has genotoxic potential at localised high concentrations and in <strong>the</strong>absence <strong>of</strong> metabolism. Pletsa (1999) reported a 3-fold increase in <strong>the</strong> mutationfrequency in <strong>the</strong> liver <strong>of</strong> transgenic mice following repeated intraperitonealinjection <strong>of</strong> dichlorvos. In this same study, a single injection failed to have aneffect, while nei<strong>the</strong>r single nor repeated administration generated methylatedDNA adducts or increased <strong>the</strong> frequency <strong>of</strong> mutations in o<strong>the</strong>r tissues. Thesefindings are consistent with increased tumours (mostly papillomas) observed in<strong>the</strong> <strong>for</strong>estomach <strong>of</strong> mice, where tissue was exposed to high concentrations <strong>of</strong>unchanged dichlorvos (NCI 1977; Chan 1989).―The extensive genotoxicity database indicates that in <strong>the</strong> absence <strong>of</strong> metabolism,dichlorvos is mutagenic and clastogenic at <strong>the</strong> point <strong>of</strong> contact, where unchangeddichlorvos may be in direct contact with tissue. There is no evidence thatdichlorvos has any systemic genotoxic potential. Scenarios <strong>of</strong> prolonged exposurein <strong>the</strong> absence <strong>of</strong> metabolic activity are unlikely in <strong>the</strong> general population given<strong>the</strong> current patterns <strong>of</strong> use. Chronic inhalational exposure (<strong>the</strong> most likelyexposure route in humans) failed to cause tumours (Blair et al., 1974) or tomethylate nucleic acids in rats (Wooder et al., 1976). The failure <strong>of</strong> dichlorvos tomethylate DNA or RNA in vivo has been attributed to its phosphorylatingreactivity, leading to highly efficient biotrans<strong>for</strong>mation (Wright et al., 1979).Fur<strong>the</strong>rmore, <strong>the</strong> consistently negative in vivo genotoxicity findings consequentwith rapid metabolism indicate that dichlorvos is unlikely to pose a genotoxic riskto humans.‖ (Originals not sighted; APVMA, 2008a)Dichlorvos reassessment – application Page 190 <strong>of</strong> 436

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