The benefits of basing quantitative risk assessment on measures of 'in
ternal dose', i.e. target organ exposures as estimated, for instance,
by pharmacokinetic models, have been extensively discussed. Recasting
risk assessment methods at the level of internal dose raises novel iss
ues, however, some of which are explored by examining the 1987 revisio
n by the U.S. Environmental Protection Agency (EPA) of its cancer risk
assessment for inhaled methylene chloride, which was based on the 198
7 pharmacokinetic model results of Andersen and coworkers. The interna
l dose measure was the daily amount of methylene chloride metabolized
by a glutathione-S-transferase pathway per 1 of target organ (liver an
d lung). Owing to high-dose saturation of a competing detoxification r
eaction, this metabolic activation is less-than-proportionally active
at low exposure levels. For a given inhalation exposure, humans have r
elatively less metabolic activation than do mice, but this is shown to
be a foreseeable consequence of their relatively lower breathing rate
, a cross-species difference already accounted for in standard EPA met
hodology. Indeed, many species differences in the rates and tempos of
physiological processes evince regular 'scaling' relationships across
differently sized mammals. EPA's practice of scaling carcinogen doses
by body surface area for cross-species extrapolation, often viewed as
a correction for metabolic activation, is shown to be more reasonably
regarded as an accommodation for the more general species variation in
the pace of physiological processes underlying both pharmacokinetics
and the carcinogenic response to internal doses. Under this view, the
issue of cross-species dose scaling is not obviated by the use of phar
macokinetics.