There is an abundant amount of information on the mechanisms of action
of genotoxic chemicals that act as carcinogens and the role that muta
tions play in carcinogenesis. However, carcinogenesis is more than mut
agenesis and many carcinogens are not mutagens. Thus, there is a need
to consider nongenotoxic mechanisms that may be involved in carcinogen
esis. In this paper, we review our working hypothesis that hypomethyla
tion of DNA is an epigenetic, nongenotoxic mechanism that plays a role
in tumor promotion by facilitating aberrant gene expression. The util
ity of employing experimental models that focus on relevant comparison
s between sensitive and resistant strains of mice is emphasized. Addit
ionally, aspects of DNA methylation in rodents and humans are compared
and contrasted. We discuss hypomethylation of DNA as a secondary mech
anism, that is expected to be threshold-exhibiting, and conclude by de
scribing how this information may facilitate a rational approach towar
ds risk assessment when dealing with nongenotoxic compounds that are c
arcinogenic in a bioassay.