Dose influences mechanism; and over a wide range of doses, one can env
ision that mechanism will change with changing dose. This basic concep
t in toxicology is juxtaposed with the biologic importance of maintain
ing normal DNA methylatiori status to provide the focus of this paper.
The idea that altered DNA methylation plays a variety of roles in car
cinogenesis is compatible with three key features of this multistage p
rocess: clonal selection of abnormal cells in a progressive fashion, t
he reversibility of tumor promotion, and the multiplicity of tumor phe
notypes. A relatively low capacity to maintain normal methylation stat
us appears to explain, in part, the high propensity of the B6C3F1 mous
e to develop liver tumors. This observation supports the view that a m
ouse liver tumor response is not an appropriate end point for human ri
sk assessment. Additionally, it is suggested that altered DNA methylat
ion can be viewed as a secondary mechanism underlying carcinogenesis.
The knowledge that a chemical is acting by a mode of action involving
a secondary mechanism can be used to support a safety factor or multip
licity of exposure approach to risk assessment.