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Complaint Investigation Summary Report #: 5105 <br />COMPLAINT ID: C00055108 Site Location: 12617 N MUNDY LN <br />Activity Summary <br />Activity Date Recorded by <br />Species: Rats <br />Critical endpoint: Hair follicle atrophy and alopecia in females (NOAEL) <br />Clinical signs (BMD) <br />Lowest Observed Adverse Effect Level (LOAEL): 0.2 mg/kg/day <br />No Observed Adverse Effect Level (NOAEL): 0.04 mg/kg/day <br />Benchmark Dose (BMD): 0.01 mg/kg/day <br />Uncertainty factor: 3000 (10x intraspecies, 10x interspecies, 3x subchronic to <br />chronic, and 10x database deficiency) <br />Confidence: Not provided — EPA (2009) states that the deficiencies in the study <br />reporting and overall database preclude deriving an RfD. <br />RfD: Not provided. Calculated values that were considered in the USEPA <br />document were: 0.01 ug/kg/day and 0.003 ug/kg/day. <br />Conclusion: The thallium levels in these kale chips explain the family's urinary <br />thallium pattern. The USEPA RfD draft values are too poorly supported to serve as <br />a firm basis for a risk calculation. The estimated daily intakes above would <br />suggest that intakes at the suggested serving size (on a daily basis) are 67x below <br />the LOAEL and 13x below the NOAEL from the MRI 1988 rat study. But the major <br />caveat is that there is low confidence in both the draft RfD and the study upon <br />which it was based. We just don't have good data from the toxicology literature on <br />thallium. <br />Oak Ridge National Labs 1994 evaluation of older RfD: <br />https://rais.ornl.gov/tox/profiles/thallium_f_V1.htnnl#t3 <br />RfD: 0.08 or 0.09 ug/kg/day. These values appear to be out of date and before <br />the 2009 USEPA review. <br />Carcinogenicity weight of evidence: Unable to classify because there was <br />"inadequate information to assess carcinogenic potential." <br />Jeff Fowles, Ph.D. <br />Staff Toxicologist <br />Environmental Health Investigations Branch <br />Center for Healthy Communities <br />Richmond, CA <br />Mark Miller MD, MPH <br />Co-Director, Western States Pediatric Environmental Health Specialty Unit at <br />University of California, San Francisco <br />ucsfpehsumiller@gmail.com <br />01/18/2023 COMPLAINT INSPECTION ABATED AT THIS TIME. NO FURTHER ACTION <br /> SOOD <br />TAKEN BY ALL RELEVANT AGENCIES AT THIS TIME. SEE EMAIL FROM <br />FAMILY THANKING THE ENVIRONMENTAL HEALTH DEPARTMENT AND <br />OTHER AGENCIES. <br />51oarpt Page 5 of 5