BUTYLATED HYDROXYANISOLE (BHA) EXPLANATION BHA was evaluated for acceptable daily intake for man (ADI) by the Joint FAO/WHO Expert Committee on Food Additives (JECFA) in 1961, 1965, 1973, 1976, 1980, 1982, 1983 and 1986 (Annex 1, references 6, 11, 32, 41, 53, 59, 62 and 73). Toxicological monographs were issued in 1961, 1973, 1976, 1980, 1983 and 1986 (Annex 1, references 6, 33, 42, 54, 63 and 74). At the 30th meeting of the JECFA (Annex 1, reference 73), a temporary ADI of 0-0.3 mg/kg bw was established pending adequate studies in pigs and monkeys to explore the potential for BHA to cause esophageal hyperplasia in these species. A multigeneration reproduction study was also required. Since the previous evaluation, new data have become available and are summarized and discussed in the following monograph. In addition, the monograph reviews special studies of the effect of BHA on the stomach of experimental animals. BIOLOGICAL DATA Biochemical Covalent binding to macromolecules Metabolites binding irreversibly to proteins were found in an in vitro study involving liver microsomes + NADPH, liver microsomes + cumene hydroperoxide, sheep seminal vesicle microsomes + arachidonic acid, or horseradish peroxidase + hydrogen peroxide (Newberne et al., 1986). In another in vitro study (Cummings et al., 1985), 3- tert-butylhydroxyanisole (3-BHA) metabolism was found to yield material which covalently bonded to protein, although the amount of these products was reduced directly in proportion to the amount of glutathione available. In a third study (Hirose et al., 1987a), however, no covalent binding to macromolecules was found in a 9000 g supernatant fraction derived from forestomach epithelium that had been incubated with 3-BHA in the absence or presence of NADPH. Looking at male F344 rats that had been given an intragastric injection of radioactively labelled 3-BHA, no metabolites were detected by thin layer chromatography in the forestomach or glandular stomach epithelium six hours after treatment. Assessing the macromolecular binding of 2- and 3-BHA, these same authors reported no binding to forestomach, glandular stomach, liver or kidney DNA or RNA, while binding to protein was similar at the four sites. They concluded that the activity of BHA is not related to any covalent binding property of BHA. In contrast to this, deStafney et al. (1986) reported that 3-BHA bound in vitro to liver microsomal proteins. In vivo, 3-BHA bound to forestomach microsomal proteins 14-fold more than to glandular stomach microsomal proteins and 12-fold more than liver microsomal proteins. With HPLC studies, these workers showed that there were peaks in the forestomach preparation that were not present in other preparations. The authors speculated that the effect of BHA was due to its ability to deplete thiols (accounting for the noticeable threshold of its effects), and the binding to tissue proteins or reactive BHA metabolites, possibly oxygen radicals resulting from the redox cycling of quinones and hydroquinones. Excretion The elimination of BHA was studied in male F344 rats (Hirose et al., 1987b). Within 48 hours of ingestion of BHA, 87-96% of the BHA was found to be eliminated via urine, feces or respiration. The isomers 2-BHA and 3-BHA labelled at either the methoxy or tert-butyl site were used. For 3-BHA and 2-BHA, respectively, 63.7% and 69.0% of the tert-butyl label was found in the urine and 28.8% and 18.1% in the feces (expired air was not examined for these isotopes). For 3-BHA and 2-BHA, respectively, 49.8% and 46.5% of the methoxy label was found in the urine, 28.3% and 29.6% in the feces, while 8.3% and 13.7% was found in expired air. In a second study in which Sprague-Dawley rats were used (Ansari & Hendrix, 1985), 41% of the methoxy labelled 3-BHA was found in the urine while 53% was found in feces 48 hours after administration by gavage. In beagle dogs, within 48 hours of an J.p. injection of methoxy labelled 3-BHA, 50-80% of the label was found in the urine and 15-30% in feces (Takizawa et al., 1985). Toxicological Studies Special studies on the effect of BHA on the stomach Mice Groups of 10 male NMRI mice received daily doses of 0 or 1000 mg BHA/kg bw for 28 days via intubation of an arachis oil solution. At the end of this period, macroscopic lesions were seen in the forestomach of the mice that resembled lesions in rats (Altmann et al., 1986). Male B6C3F1 mice were exposed to 0.5 or 1% BHA in their powdered diet for 104 weeks and groups of 10 animals were examined at 8 week intervals. Hyperplasia of the forestomach was first seen in the group exposed to the highest level of BHA after 64 weeks exposure at which time 30% of the animals showed this effect. Papillomas were observed in mice at both concentrations at week 80 and were found in 10-40% of the animals thereafter. Carcinomas were detected beginning with week 88, but not in numbers significantly different from concurrent controls (a total of one carcinoma among all the low level groups and two among the high). The carcinomas seen were all well-differentiated. The authors state that the number of carcinomas is significant if compared to their historical control data (0 tumours in 244 mice) (Masui et al., 1986b; Ito et al., 1986b; Ito & Hirose, 1987). Rats Male Fischer 344 (F344) rats were divided into groups of 5 and were fed diets (corn oil, pellets, or powder) containing 0, 0.1, 0.25, 0.5, 1 or 2% BHA. After 9 or 27 days, they were sacrificed and their forestomachs examined histologically for proliferative changes in the squamous epithelium (Clayson et al., 1986). Groups of 5-15 rats on the same diet regimen were injected with radioactively labelled thymidine just prior to sacrifice and their forestomach squamous epithelia examined for incorporation of the label (the labelling index). Thymidine is taken up by replicating cellular DNA, the presence of which is indicative of induced cell proliferation. No effects on the labelling index were seen in rats fed 0.25% BHA or less for 9 days. Histopathologically, hyperplasia was observed only at 0.5% BHA and above, with the size of the forestomach area involved being proportional to the dose. After 9 days of exposure to 2% BHA in pellets, a localized four-fold thickening of the mucosa was found along the lesser curvature of the forestomach. Papillae and irregularly spaced rete ridges, acanthosis and hyperkeratosis were observed. Many mitotic figures were seen in the otherwise normal-appearing basal layers. There was also acute inflammatory cell infiltration in the underlying layers. After 27 days, the now six-fold thickening had spread widely, being visible most markedly adjacent to the forestomach-fundic stomach junction. After 9 and 27 days with a pellet diet containing 2% BHA, the labelling index had been increased approximately eight-fold in the pre-fundic region. With BHA given via corn oil, the labelling index after 27 days was only increased four-fold; however, the thickening had increased over twelve-fold in the prefundic region. In the mid-stomach region, the effect of corn oil vs. pellet feeding of BHA on the labelling index was similar (two-fold), while thickening was less pronounced with corn oil (four-fold vs. nine-fold). There were no significant differences between the effects of BHA given by pellet and given by powdered diet. Male F344 rats in groups of 5 were exposed to 2% BHA in a powdered diet for 4 weeks in another study (Hirose et al., 1987c). Severe hyperplasia was observed mainly in the prefundic region of the stomach near the esophageal orifice. The forestomach showed whitish-colored thickening of the epithelium around the orifice of the esophagus and the limiting ridge of the forestomach, while focal patchiness was observed in the central region. Significant body weight gain reduction was also observed in these animals, although the liver weight was significantly increased compared to controls. In a third study (Clayson et al., 1986), groups of 5 male F344 rats were fed 0, 0.1, 0.25, 0.5 or 2% BHA (powder) for 13 weeks. Body weight gain was seen to be significantly reduced in animals fed 2% BHA. Proliferative lesions also only developed in the forestomach epithelium of the 2% group. In these animals, there was thickening in the squamous epithelium and downward proliferation of the basal cells. Papillae and rete pegs as well as hyperkeratosis were also observed. The muscular layer of the forestomach, however, was normal. The labelling index was increased in animals exposed to no less than 0.5% BHA, being 2.5x normal after 9 days and 5.3x after 91 days in the animals exposed to 2% BHA. One week after animals were removed to normal for all exposure groups, but the mucosal lesions reverted more slowly, still being visible even 9 weeks after cessation of exposure. As a follow up to this, Clayson et al., (1986) examined the forestomachs of rats that had been fed 2% BHA for 3 months and then basal diet for 12 months, and BHA for 6 months followed by basal diet for 9 months. The forestomachs of both of these groups were histologically nearly normal, with the 6 month treatment group showing a few downward projections from the normal-appearing epithelium. Two rats that had been exposed to 2% BHA for 12 months and then basal diet for 3 months, however, had squamous cell carcinoma of the forestomach, while others had papillary growths showing a high rate of proliferation as shown by thymidine labelling. In another study (Masui et al., 1986a; Ito & Hirose, 1987), 10 male F344 rats were given a pellet diet containing 2% BHA for 24 weeks. Another 20 received the same diet for 24 weeks and then were given food without BHA for 72 weeks to assess the effect of removing animals from BHA exposure. The forestomach of rats given BHA for 24 weeks showed epithelial thickening, especially at the limiting ridge. Only slight thickening, however, was seen near the limiting ridge in animals exposed to BHA and then removed from exposure for 72 weeks. Rats exposed to BHA for 24 weeks developed hyperplasia and papillomas in their forestomachs. These changes included upward proliferation with thickening of the stratified squamous epithelium often with interstitial proliferation, and downward proliferation of basal cells forming elongated ridges. Acute inflammatory reactions in the lamina propria or submucosa were also seen. In animals whose exposure was discontinued, upward proliferation of hyperplasia and papillomas had completely disappeared. Downward proliferation of basal cells persisted, however, in all rats, and papillomas were observed in 3 of the rats examined. In this group, however, no inflammation was observed, no dysplastic changes were seen in basal cells and no cancer was observed. In a similar study (Ito et al., 1986a; Tamano et al., 1986), other workers reported that after 104 weeks exposure to 0, 0.125, 0.25, 0.5, 1 or 2% BHA given by powdered diet to groups of 50 male F344 rats, body weight gains over the period of observation were depressed in a dose-related manner, being statistically significant in rats receiving at least 0.5% BHA, even though there was no significant difference in food intake among any of the groups and non outward clinical symptoms. No significant pathology compared to controls was seen in animals fed BHA at any site other than the forestomach epithelium and significant forestomach damage was only seen in animals exposed to more than 0.5% BHA. This damage took the form of extensive raised lesions and was expressed in a dose-related manner with the most severely affected region being at the limiting ridge. At the end of the 104 week exposure period, 100% of the animals exposed to 2% BHA had hyperplasia visible in the forestomach, 100% had papillomas, and 22% also displayed squamous cell carcinoma. These carcinomas were well differentiated, displaying keratinisation. No metastases were discovered, however. Animals exposed to 1% BHA showed 88% hyperplasia, 20% papilloma, but no carcinoma was seen. For rats exposed to 0.5%, 0.25% and 0.125% BHA, 32%, 14% and 2%, respectively, had hyperplasia visible, but no more severe lesions were reported. This work was confirmed by a study in which male F344 rats were exposed to 1 or 2% BHA in a powdered diet for 104 weeks with animals sacrificed in groups of 10 every 8 weeks during the course of the study (Masui et al., 1986b; Ito et al., 1986b). Hyperplasia of the forestomach was observed in a few animals of both treatment groups at the first observation time, 8 weeks after the start of the exposure. It was present in almost all animals examined from the high level exposure group from 16 weeks exposure onward and from 40 weeks exposure onward for the low level exposure group. In the high level group, papillomas were first seen at week 8 and were present in virtually all animals examined in this group week 32. No papillomas were seen in the low level group for the first 48 weeks, but they were seen in 80-90% of all animals examined after week 56. The first animal with squamous cell carcinoma, seen only in the animals exposed to 2% BHA, was observed at week 48 and a second animal was observed at week 80, with the incidence slowly increasing thereafter so that by 104 weeks, 14% of the animals examined displayed this pathology. No changes of any kind were seen in the glandular stomach of any animal of any group. A 104 week exposure of male and female F344 rats to 0.5 or 2% BHA in pellets was also reported (Ito et al., 1982; Ito et al., 1983; Ito et al., 1985; Ito & Hirose, 1987). There were approximately 50 rats per exposure group. The mean body weights of both sexes, were reduced in those animals given 2% BHA with the difference being significant after 16 weeks on the diet. At the end of the exposure period, 100% of the males and 98% of the females exposed to 2% BHA displayed hyperplasia in the forestomach. By comparison, only 26% of the males and 20% of the females exposed to 0.5% BHA had hyperplasia. For papillomas, 100% of the males and 96% of the females exposed to 2% BHA displayed this type of lesion, while 2% of the animals of both sexes exposed to 0.5% BHA. had this observation. Squamous cell carcinoma was seen only in animals exposed to 2% BHA and was observed in 35% of the males and 30% at that dose level. Grossly, most tumours were seen in the area of the limiting ridge of the forestomach. Tumours were greyish-white with nodules. Histologically, squamous cell carcinomas were sometimes well-differentiated and sometimes not. Those that were well- differentiated were keratinized with nuclear atypia and many mitotic figures present. Infiltration into the muscular layer and fatty tissue was seen. Three cases of metastases were observed. No significant incidence of tumours in any other organ were seen in any group. These diagnoses were also independently confirmed (Moch, 1986). Groups of 5-10 male and female Wistar rats were fed 2% BHA in a powdered diet for 1, 2 or 4 weeks (Altmann et al., 1985; Altmann et al., 1986). After 1 week, epithelial damage with mild hyperplasia and hyperkeratosis, and blood-filled cystic swellings were observed in the forestomach and livers were markedly enlarged. Progression of the hyperplasia and hyperkeratosis was seen after 2 weeks. Body weight of those fed BHA was also significantly depressed. At 4 weeks, severe diffuse hyperplasia, acanthosis and hyperkeratosis in the forestomach mucosa, with the most pronounced lesions in the area of the limiting ridge, were seen. The effects seen, including weight differences, almost completely regressed, however, after an additional 4 weeks without BHA. In a second experiment, groups of 3 male rats received intubations of 1 g BHA/kg bw/day in arachis oil for 1, 2, 4, 8, 16 or 32 days. After only one day, increased mitotic activity, and, after 2 days, mild hyperplasia were seen in the forestomach. Inflammatory responses and superficial effects were not prominent, however, and the authors believe that the hyperplasia of the squamous epithelium did not result from the initial damage and subsequent regenerative activity. After the fourth intubation, the entire wall of the forestomach was thickened, wrinkled and swollen. After 8 days, the hyperplastic changes regressed. With the arachis oil gavage, the lesions appeared remote from the limiting ridge. Four weeks following the cessation of BHA intubation, the forestomach showed almost complete regression with only mild hyperplasia remaining. At no time during any of these experiments were changes seen in the glandular stomach or esophagus and there were no differences between the sexes. In a 90 day feeding study (Altmann et al., 1986), groups of 10 male and 10 female Wistar rats received 0, 0.125, 0.5 or 2% BHA in crystalline form. The highest concentration led to marked hyperkeratosis and hyperplasia with epithelial dysplasia in some basal areas of the forestomach. Less pronounced lesions were seen at 0.5% and only mild lesions were seen in the 0.125% group. In a second experiment, 0, 0.025, 0.125 or 2% BHA was administered to groups of 20 male or 20 female rats dissolved in arachis oil. Again, pronounced hyperplasia was seen in the forestomach in the high dose group. None of the lower dose levels of BHA had any effect. In only one of the rats was the esophagus affected. In a study of reversibility of BHA damage, groups of 5 male and 5 female Wistar rats fed 2% BHA for 6, 12 or 15 months showed almost complete reversal of severe lesions of the forestomach after withdrawal from BHA for 7 months. In another study (Takahashi et al., 1986), male Wistar rats (10 per group) were fed 1 or 2% BHA (powder) for 32 weeks. A weight gain retardation in those animals receiving BHA was reported as were thickenings in the squamous cell mucosa of the forestomach as well as the presence of squamous cell papillomas. Neoplasms in animals receiving 2% BHA occupied most of the forestomach. These lesions villous nodules that were greyish-white in color. The surface epithelium showed hyperkeratosis with necrosis at the superficial layer and long processes of squamous cell epithelium. The incidence of papillomas was 100% in this group. Four cases (20% incidence) ofdownward growth into the submucosa were also seen. Animals on 1% BHA had single or multiple polypoid tumours in the forestomach with a 40% incidence of papillomas. No lesions in the glandular stomach or duodenum were seen in any exposure group. The development of forestomach lesions was found to be significantly quickened when Wistar rats in groups of 10 were subjected to a 2/3 partial hepatectomy and then fed 2% BHA in a powdered diet (Abraham et al., 1986). Under these conditions carcinomas were seen after only 3 months. No body weight gain depression was reported in this study, however. While only slight hyperplasia was seen in the forestomachs of animals after receiving BHA alone, those that were fed BHA following partial hepatectomy showed grossly visible tumours of the forestomach. In these latter animals, the forestomach mucosa was thickened and white in color with confluent nodular masses. All ten of the animals exposed to 2% BHA following partial hepatectomy displayed hyperplasia and had papillomas with marked hyperkeratosis. Half of the animals showed carcinoma as well. The carcinomas were well differentiated with dysmorphic changes, nuclear atypia and mitotic activity. Infiltration of the carcinoma in the muscle layer and fatty tissue was seen. Granulocyte, lymphocyte and macrophage infiltration of the submucosa was also reported. All other organs were normal in appearance. A group of 30 male Sprague-Dawley rats was given 1% BHA for 3 months (Newberne et al., 1986). At the end of this exposure period, 66% of the animals had hyperplasia of the forestomach, 26% also showed papillomas, and 6% also had carcinomas. The labelling index showing cells of the forestomach that were undergoing active DNA synthesis in those animals exposed to BHA was over 11 times higher than in control animals. In a separate experiment, animals administered BHA by gavage were found to be even more severely affected than those fed BHA in the diet. In the former group 12/18 animals were found to have carcinomas while only 2/20 in the latter had similar problems. Hamsters A group of Syrian golden hamsters received a diet of 2% BHA for 28 days (Altmann et al., 1986). At the end of this period, macroscopic lesions in the forestomach of the hamsters were seen but were reported to be different from those in rats and mice. No hyperkeratosis was seen in the hamsters macroscopically, but the mucosae were less elastic and sometimes thickened and wrinkled. Macroscopically, mild hyperplasia and hyperkeratosis were observed. These were more pronounced in the females. In another study (Hirose et al., 1986d; Ito et al., 1986b), groups of approximately 30 male Syrian golden hamsters were fed 1% BHA in a powdered diet for 1 or 3 days or 1, 2, 3, 4 or 16 weeks after which they were injected with radioactive thymidine (to enable a labelling index to be ascertained), sacrificed and examined. Animals exposed to BHA showed a body weight decrease compared to controls, but a liver weight increase. Focal thickening of the forestomach epithelium with or without ulceration and occasional covering with a dense keratin-like greyish-white substance was seen in hamsters exposed for at least 1 week. There were no abnormalities in any other organs examined. Severity of hyperplasia gradually increased with time of exposure. Papillomas were seen beginning with week 4. Neutrophil infiltration was also observed. An increase in the labelling index paralleled the severity of the lesions observed. In a similar study (Hirose et al., 1986b), fifteen hamsters were given a powdered diet containing 1% BHA for 20 weeks with 3 being injected with radioactive thymidine just prior to sacrifice for labelling index determination. Again, body weight depression was seen in animals fed BHA. Thickening of the forestomach epithelium with white, keratin-like substance was also noted. All of the animals displayed severe hyperplasia with 60% additionally showing papillomatous lesions. The labelling index in the forestomach was almost three times that in control animals. No changes were seen in any other organ examined. These observations were extended to 104 weeks exposure to 1 or 2% BHA (powder) in the next study (Masui et al., 1986b; Ito & Hirose, 1987). Groups of 10 male hamsters were observed at 8 week intervals. In these animals, hyperplasia of the forestomach was observed in all animals in both exposure groups starting at 8 weeks of exposure. Papillomas were likewise seen in almost all animals in the high level exposure group beginning at week 8, and in the low level group from week 16. Hyperkeratosis and downward growth of the tumour into the submucosa was often observed. Squamous cell carcinomas were observed in both treated groups beginning in week 64. They were well differentiated and an invasion of the liver was seen in one case. After 104 weeks of exposure, hyperplasia was seen in 100%, 96% and 17% of the 2%, 1% and control animals, respectively. Likewise, 95%, 98% and 0% of these groups showed papillomas, and 10%, 7% and 0%, respectively, carcinomas. Guinea pigs Guinea pigs fed a diet containing 1% BHA for 20 months did not exhibit any gross changes in the stomach (Ito & Hirose, 1987). Dogs Groups of 29 male and 30 female beagle dogs (also lacking a forestomach), were fed 0, 1.0 or 1.3% BHA for 180 days (Ikeda et al., 1986; Moch, 1986). Food consumption and body weight gain were reduced in the animals receiving the highest level of BHA and there was a liver weight increase in animals receiving BHA at either dose. Ultrastructural examination of the livers of animals on BHA showed proliferation of smooth endoplasmic reticulum and hepatocytic cytoplasmic myelinoid bodies. Light and electron examination of the stomach and lower esophagus showed no proliferative or hyperplastic lesions and no change in the number of cells. BHA at 0.25, 0.5 or 1.0% was fed to groups of 3-4 male or female beagle dogs for six months in a second study (Tobe et al., 1986). A dose-related retardation of growth was reported. Liver weights were increased but no histopathological changes were seen in that organ. There were no alterations in the stomach mucosa and there was no induced change in the mitotic index of the squamous epithelium of the distal esophagus. In a third report, adult beagle dogs fed a diet containing 0-100 mg BHA/kg bw/day for one year exhibited no histopathological changes in any tissue examined (Ito & Hirose, 1987). Pigs Three different experiments were conducted involving pregnant young adult specific pathogen free (SPF) Danish Landrace gilts (Olsen, 1983; Wurtzen & Olsen, 1986; Moch, 1987). Combining the data of the three studies, groups of 9-13 pigs were fed pellets containing 0, 0.5%, 1.9% or 3.7% BHA (0, 50, 200, or 400 mg BHA/kg bw/day, respectively) for the first 110 days of pregnancy. Epithelial changes in the esophageal part of the stomach were similar for test and control groups. No papillomas and no changes in the oesophageal part of the stomach were similar for test and control groups. No papillomas and no changes in the glandular part of the stomach were reported. Linear yellow-brown, rough epithelium was seen in the entire length of the esophagus in a few pigs in the middle and high dose groups. In the first of the three experiments, one of the three animals in the middle dose group and two of three in the high dose group had esophageal lesions seen at gross necropsy. All three of these animals had histopathological examination of the esophageal lesions seen at gross necropsy and were diagnosed as having esophageal hyperplasia. In addition, one other, animal in the middle dose group had esophageal hyperplasia noted microscopically, although no lesion was seen at time of gross necropsy. In the second experiment, one of the three animals in the high dose groups had an esophageal lesion noted at gross necropsy. In the second experiment, one of the three animals in the high dose groups had an esophageal lesion noted at gross necropsy. No histological examination of this animal was performed, however. In the third experiment, one of the seven animals in the middle dose group and one of four animals in the high dose group had a lesion of the esophagus seen at gross necropsy. None of these animals had histological examination of the reported lesions. The authors concluded on the basis of the one middle dose level pig and the two high dose level pigs of the first study that BHA might have an effect on esophageal epithelium. Monkeys Groups of 8 female cynomogus monkeys were given 0, 125 or 500 mg BHA/kg bw by gavage in corn oil 5 times/week for 20 days, after which the dose was halved and continued for a total of 85 days (Iverson et al., 1986; Ito & Hirose, 1987). Although there were transitory dose-related changes in blood clinical values during the first part of the exposure, no value differed from the normal range nor were any abnormal fibroscopic observations made during the course of the exposure. Histopathological examination at the end of the exposure period showed no treatment related effects, although the mitotic index in the basal cell layer of the squamous epithelium of the distal esophagus was elevated by a factor of 1.9. Liver weight was also increased in animals exposed to BHA in a dose-related manner. Special studies on the effect of the molecular structure In Syrian golden hamsters (Hirose et al., 1986d), the observation was made that, in parallel with its relative power as an antioxidant, 3- tert-butylhydroxyanisole (3-BHA) is significantly better able to cause biological damage than 2- tert-butylhydroxyanisole (2-BHA). Using radioactive labelling in F344 rats, however, 2-BHA has been shown to be incorporated into cells of the forestomach after 1 week of treatment at approximately twice the level of 3-BHA (Hirose et al., 1987b). Food grade BHA is primarily composed of 3-BHA. Three papers have reported investigations attempting to discover which part(s) of the chemical structure of BHA is critical to its actions. By comparing the ability of 13 structurally related phenolic compounds to cause lesions in the forestomach of Syrian golden hamsters after 20 weeks exposure, one report (Hirose et al., 1986b) concluded that the phenolic compounds must have both at least one hydroxy and exactly one tert-butyl substituent to have strong activity in inducing forestomach tumours. Other structural variations produce their own spectra of biological consequences (Ito & Hirose, 1987). In the other two papers on this subject (Altmann et al., 1985; Altmann et al., 1986) in which Wistar rats were fed one of 12 chemicals related to BHA or BHA itself, the conclusion is made that the critical part of the BHA structure is the methoxy group. Special studies on potentiation or inhibition of carcinogenicity The ability of BHA to interact with known carcinogens has been studied extensively (Lindenschmidt et al., 1987; Hirose et al., 1986c; Ito et al., 1986b; Tsuda et al., 1987; Fukushima et al., 1987; Hirose et al., 1986a; Tsuda et al., 1984; Newberne et al., 1986; Takahashi et al., 1986; Moore et al., 1986; Ito et al., 1985; Williams et al., 1986; Masui et al., 1986c; and Chung et al., 1986). Several strains of rats and mice of both sexes have been fed BHA at various concentrations for various durations either before, after, or before, during and after treatment by various routes with various concentrations of several carcinogens administered for various lengths of time. The net effect of BHA plus the carcinogen has been examined in thirteen organs. What has been found is that BHA potentiates, inhibits, or has no effect on the ability of the carcinogen to act, depending on the exact chemical being tested and the circumstances under which the test is being conducted. COMMENTS Studies have been conducted that provide additional information on the proliferative changes observed in the forestomach of rats fed BHA. No new studies on the effect of BHA on the stomach and esophagus of species that do not have a forestomach, e.g., pigs or monkeys, were conducted. The data show that continuous exposure of the rat forestomach to 2% BHA in the diet for 6-12 months is necessary to produce squamous cell carcinoma. The data also show that the induction of mild hyperplasia can occur at levels of 0.125% of BHA in the diet but not at a level of 0.1% BHA. After reevaluating the data in pigs, it was concluded that the evidence that BHA produces hyperplasia in the esophagus of the pig is questionable. Moreover, these presumptive effects in pigs were reported to occur at levels of BHA significantly higher than those that produced the confirmed effects in the rat forestomach. Considering the absence of any significant adverse effects in two dog studies, it was concluded that further investigations in animals without forestomachs are not required. The human relevance of the rat studies, while inherently questionable because the target tissue in the rat has no human counterpart, cannot readily be ignored. Based on the dose dependence and reversibility of the lesions produced in the rat, discussed previously in the 1986 monograph (Annex 1, reference 74) and since confirmed by more recent studies, it was concluded that an ADI can be established. EVALUATION Level causing no toxicological effect Rat: 0.1% in the diet, equivalent to 50.0 mg/kg bw/day. Estimate of acceptable daily intake for man 0-0.5 mg/kg bw. 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See Also: Toxicological Abbreviations Butylated hydroxyanisole (WHO Food Additives Series 5) Butylated hydroxyanisole (WHO Food Additives Series 10) Butylated hydroxyanisole (WHO Food Additives Series 21) BUTYLATED HYDROXYANISOLE (JECFA Evaluation)