49, 102–109 (1999) Copyright © 1999 by the Society of Toxicology TOXICOLOGICAL SCIENCES Delayed Acute Toxicity of 1,2,3,4,6,7,8-Heptachlorodibenzo-p-Dioxin (HpCDD), after Oral Administration, Obeys Haber’s Rule of Inhalation Toxicology Karl K. Rozman 1 Department of Pharmacology, Toxicology, and Therapeutics, University of Kansas Medical Center, Kansas City, Kansas 66160; and Section of Environmental Toxicology, GSF-Institut für Toxikologie, Neuherberg, 85758 Germany Received September 4, 1998; accepted January 8, 1999 Eight different doses (2.5 to 10.0 mg/kg) of 1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin (HpCDD) were administered acutely to a total of 272 female Sprague-Dawley rats. The doses ranged from a NOAEL for wasting/hemorrhage to supralethal doses. Dose-and time-responses of wasting/hemorrhage, anemia, and cancer were and are being studied as end points of toxicity. The experiments will be continued until the last rat dies. There was a very steep dose- and time-response between the LOAEL for wasting/hemorrhage (2.8 mg/kg) and the third highest dose (4.1 mg/kg) of HpCDD. The dose-and time-responses were nearly symmetrical, obeying Haber’s Rule of inhalation toxicology (c 3 t 5 constant) even beyond 100% mortality. Introduction of a minimum of 25% body weight loss as a discriminatory criterion to separate wasting from hemorrhage as the primary cause of death reduced variability from 5.8 to 3.2%. An arithmetic plot of the dose and time data resulted in a nearly perfect hyperbola. A logarithmic plot of these data yielded a straight line of similar perfection. Dose-response data at constant times illustrate the shifting of the dose-response curve towards a liminal value, which represents the necessary observation period for this effect. Time-response data at constant doses demonstrate the shifting of the time-response curve towards a liminal value, which represents the LOAEL for the dose-response of this effect. A three-dimensional plot of dose- and time-response data depicts the surface area on which c 3 t is constant along hyperbolas, in terms of wasting as the end point of toxicity. Surviving rats in all groups started developing anemia 126 days after dosing, but no rat died of wasting/hemorrhage after day 74. Rats surviving anemia began to die of lung cancer as of day 397 after dosing. Thus, although the experiment has been completed as far as dose- and time-responses of wasting/hemorrhage are concerned, it will be about another 2 years before complete dose and time responses will become available for anemia and lung cancer. Key Words: 1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin (HpCDD) toxicity; Haber’s Rule; oral administration; anemia; wasting/ hemorrhage; rat. The first widely circulated statement about the role of time in toxicology (inhalation concentration of war gases 3 exposure time 5 constant) is attributed to Haber (1924), although some awareness of it was present earlier as indicated by the work of Warren (1900) and Ostwald and Dernoscheck (1910). Warren (1900) studied the toxicity of sodium chloride in Daphnia magna (Straus). Ostwald and Dernoscheck (1910) also investigated the toxicity of sodium chloride, both in Daphnia magna and Gammarus. Flury and co-workers examined the relationship between toxic effects, dose, and time, stated as inhalation concentration (c) 3 time (t) 5 constant, for a large number of gases and vapors, mainly in cats. They confirmed this relationship for a number of compounds but also found many exceptions (e.g., Flury and Wirth, 1934). The toxicological endpoints measured were usually anesthesia and death. Haber’s Rule eventually fell in disfavor to the point that most recent textbooks of toxicology do not even mention it. The c 3 t concept emerged again in an entirely different area of toxicology, namely in cancer research. Druckrey and Küpfmüller (1948) reported that the latency period of butter yellow-induced cancer occurred in agreement with the dose 3 time 5 constant concept, i.e., increasing doses resulted in a decreasing latency period, but the overall product of dose 3 time remained constant. However, Druckrey (1967) also found many exceptions to this rule and eventually suggested that the latency period in cancer formations obeys the general rule of dose 3 time x 5 constant, where x can assume values between 1 and up to about 6. Recent reliance on the linear no-threshold dose-response assumption, which was introduced in cancer risk assessment by Crump et al., (1976) effectively ended this line of research, because it included the underlying assumption that time was not a variable at low doses. This assumption is in stark contradiction to the herein-presented c 3 t concept. The latter implies that there is a dose that will have no effect: during the natural life span of a given species. This dose, according to this concept, is a practical threshold dose: 1 Address correspondence to Department of Pharmacology, Toxicology and Therapeutics, University of Kansas Medical Center, Kansas City, KS 66160 – 7417. Fax: (913) 588-7501. E-mail: [email protected]. 102 cthreshold 5 constant tlifespan 103 HABER’S RULE IS VALID FOR HpCDD TOXICITY Dose and time dependencies in the form of c 3 t x 5 constant kept surfacing in other large cancer studies such as the ED 01 (Littlefield et al., 1980) and the BIBRA Study (Peto et al., 1991). The ED 01 Study was the largest toxicology experiment ever conducted, examining the carcinogenicity of 2-acetaminofluorene in about 25,000 mice. The Bibra Study used about 4000 rats to investigate the carcinogenicity of nitrosamines. In a series of papers, Rozman et al., (1993, 1996); Rozman and Doull (1998) and Rozman (1998) suggested that the relationship c 3 t 5 constant might be generalizable for all of toxicology, and as such it could be a reflection of a fundamental characteristic of nature. In these experiments, the a priori hypothesis was tested that the c 3 t 5 constant relationship is valid for the delayed acute toxicity of a highly lipophilic chemical of very long half-life, after oral administration. The rationale for these criteria was that the observation period had to be much shorter than the half-life of a compound, in order to provide near steady state conditions after acute oral dosing. Because it satisfied these criteria, and because a previous study indicated that the development of preneoplastic foci occurred in female Sprague-Dawley rats according to c 3 t 5 constant in terms of the surface area of ATPase-deficient foci (Rozman et al., 1996), 1,2,3,4,6,7,8-heptachlorodibenzop-dioxin (HpCDD) was chosen as a prototype compound. MATERIALS AND METHODS Chemicals. 1,2,3,4,5,6,7,8-heptachlorodibenzo-p-dioxin (HpCDD), CAS No. 35822– 46 –9, mw 425.4, purity 98.7%, was obtained from Cambridge Isotope Laboratories Inc. (Woburn, MA). Analysis by GC/MS at the GSFInstitut für Ökologische Chemie (85758 Neuherberg, Federal Republic of Germany) revealed that the impurities structurally related to HpCDD were different isomers of hexachlorodibenzo-p-dioxin (HxCDD) (1,2,4,6,7,9HxCDD 0.020%; 1,2,3,6,7,9-HxCDD, 0.032%; 1,2,3,4,7,8-HxCDD, 0.144%; 1,2,3,6,7,8-HxCDD, 0.079%; 1,2,3,7,8,9-HxCDD, 0.152 %, and 1,2,3,4,6,7HxCDD, 0.021) and octachlorodibenzo-p-dioxin (0.173%). These impurities accounted for 0.621% of the material. This HpCDD batch did not contain any detectable amounts of tetrachlorodibenzo-p-dioxin (TCDD) and pentachlorodibenzo-p-dioxin isomers. Animals. A total of 272 female Sprague-Dawley rats (body weight 270 – 310 g) were obtained from Harlan (Indianapolis, IN). Rats were acclimated to experimental conditions for one week. During acclimatization and throughout the experiments their health status and body weight (bw) were monitored. Rats were kept individually in stainless steel, wire-bottom cages (17.5 3 25.5 3 17.5 cm; Shoreline, Kansas, City, MO). They received Purina 5001 rodent chow (Ralston Purina, St. Louis, MO) and water ad libitum. The room was artificially illuminated from 6 A.M. to 6 P.M. and air-conditioned with a Honeywell Delta Net W1044 computer controller (Honeywell, Minneapolis, MN) programmed to maintain ambient temperature at 21–22°C and relative humidity at 40 – 60%. Dosing. The total dose of HpCDD was dissolved in corn oil and administered by gavage at 4 ml/kg, as 4 dose rates, at 12-h intervals during the first 2 days of the experiments. Lack of sufficient solubility required this dosing schedule. The second day of dosing was considered the starting point (day 0) of each experiment. Different total doses were given to groups of 30 to 60 rats. The various dosage groups were started at least 1 month apart. The doses administered and the number of animals (in parentheses) were as follows: 10.0 (30), 5.0 (30), 2.5 (30), 3.8 (30), 3.1 (30), 3.4 (32), 4.1 (30), and 2.8 (60) mg/kg. TABLE 1 Dose- and Time-Responses of HpCDD-Induced Wasting/Hemorrhage Dose (mg/kg) Mortality (%) Time to death (days) c3t (mg/kg 3 day) 2.5 2.8 3.1 3.4 3.8 4.1 5.0 10.0 0 8.3 31.0 65.6 83.3 96.7 100.0 100.0 N/A 40.2 6 6.3 a 44.3 6 6.6 29.1 6 2.9 23.4 6 1.5 25.2 6 1.9 18.6 6 0.6 10.8 6 0.3 N/A 112.6 137.3 98.9 88.9 103.3 93.0 108.0 Note. Average c 3 t: 106.0 6 6.1; N/A, not applicable. a Mean 6 SE. One rat died of gavage errors in the 3.1 mg/kg dosage group shortly after dosing and was excluded from the study. The batch of rats ordered for the 3.4 mg/kg dosage group contained 32 rats. All of them were used. The number of rats in the 2.8 mg/kg dosage group was increased from an average of 30 to 60 rats, for reasons to be discussed. The first 3 doses were selected for purposes of dose range finding. The 10and 5-mg/kg doses of HpCDD caused 100% mortality due to wasting/hemorrhage, and 2.5 mg/kg represented a NOAEL for this effect. Initially, doses were calculated on mg/kg basis. Therefore, the next dose (3750 mg/kg) was the midpoint between 5000 and 2500 mg/kg, which was rounded up to 3.8 mg/kg. The other doses were selected so that the dose changed by multiples of 312.5 mg/kg. Numbers were rounded up or down to avoid unwieldy calculations of c 3 t. The sequence of dosing the various groups of rats was carried out in the order depicted above. This sequence of dosing defined the upper curvature of the dose-response curve first, which generated the hypothesis that the last dose (2.8 mg/kg) would cause the death of 2 or 3 rats in a group of 30 rats, as a result of wasting/hemorrhage. Observations. Rats were weighed daily and their feed intake measured. They were also carefully examined daily for signs of hemorrhage. Mortality was recorded twice daily, mostly between 6 and 8 A.M. and 8 and 10 P.M., including weekends. Each of the dead rats was necropsied and macroscopically examined for intestinal hemorrhage and for the presence or absence of abdominal fat depots. RESULTS Table 1 depicts original dose- and time-response information without any attempt to distinguish between various causes of death. There are 3 different causes in chlorinated dibenzo-pdioxin (CDD)-treated rats in acute/subchronic studies: wasting, hemorrhage, and anemia (Viluksela et al., 1997,1998). The dose-responses for wasting and hemorrhage are overlapping but not with that of anemia. Anemia is clearly separated from the two former effects by time, because none of the rats died of wasting and/or hemorrhage after day 126, which is when the first rat died of anemia. In addition, rats dying of anemia or hemorrhage have macroscopically-identifiable fat depots, whereas rats dying of wasting do not. There is a very steep dose-response for HpCDD-induced mortality between 2.8 mg/kg and 4.1 mg/kg. The lowest dose 104 ROZMAN TABLE 2 Dose and Time Course of Wasting in HpCDD-treated Rats Dose (mg/kg) Death due to wasting (%) Time to death (days) c3t (mg/kg 3 day) 2.5 2.8 3.1 3.4 3.8 4.1 5.0 10.0 0 8.3 20.7 56.3 83.3 86.7 100.0 100.0 N/A 40.2 6 6.3 a 33.0 6 4.4 29.2 6 3.2 23.4 6 1.5 23.7 6 1.8 18.9 6 0.7 10.9 6 1.4 N/A 112.6 102.3 94.3 88.9 97.2 94.5 109.0 Note. Average c 3 t: 99.8 6 3.2; N/A, not applicable. a Mean 6 SE (2.5 mg/kg) represents a NOAEL for the delayed acute toxicity of HpCDD (Table 1). It is remarkable how consistent the relationship of dose 3 time 5 constant (5106 mg/kg 3 day) is from supralethal doses, all the way down to a dose of 2.8 mg/kg. In order to separate the two competing dose responses (wasting and hemorrhage), a body-weight loss of at least 25% was chosen as an inclusion criterion for rats considered dying primarily of wasting (Viluksela et al., 1997,1998). Table 2 demonstrates that this reduced the variability (mean 6 SE) of the dose 3 time 5 constant data from 5.8% to 3.2%. Figure 1 depicts the dose- and time-response information of Table 2 graphically. The upper panel displays a typical sigmoid dose-response curve, whereas the lower panel shows a timeresponse curve of very similar shape. Both the dose- and time-response curves are highly symmetrical in themselves and nearly symmetrical, in relation to each other. No error bars are shown in the lower panel depicting the time-response because the variability is shown in Table 2. Figure 2 shows that the arithmetic plot of dose vs. time yields a hyperbola (upper panel) with a nearly perfect correlation coefficient (r 2 5 0.98) and that the logarithmic plot (lower panel) of the same data results in a straight line (r 2 5 0.98), which is more familiar to toxicologists (Hayes, 1991). Figure 3 examines the dose-response data at constant times in a traditional log (dose)/effect plot. With increasing dose, there is a shift in the dose-response curve towards a liminal value, which represents the minimum observation period needed to conduct experiments using HpCDD as the toxic agent and wasting/hemorrhage as the end point of toxicity. Figure 4 examines the time-response data at constant doses in a log(time)/effect plot. It illustrates the flattening of the time-response curve toward a liminal value, which will be obtained at the LOAEL, in terms of dose response for this compound and this effect. A three-dimensional presentation of the dose- and timeresponse data can be seen in Figure 5. Having two dependent variables (response and time) increases variability as shown by irregularities of the surface area. Nevertheless, dose responses at constant times and time responses at constant doses are also apparent in this particular perspective. DISCUSSION The hypothesis that HpCDD exerts its delayed acute toxicity according to Haber’s Rule of inhalation toxicology was confirmed (Table 1). Some toxicologists might object to using the term “acute toxicity” involving an observation period of close to 100 days. However, the traditional observation period of 14 days in acute toxicity studies is entirely arbitrary. It is the half-life of a compound and/or the recovery half-life of an effect that determines the length of an observation period needed after acute exposure. In this particular instance, a 14-day observation period is not meaningful when the last rat does not die of wasting/hemorrhage until day 74 after dosing. FIG. 1. Dose- and time-response in female Sprague-Dawley rats administered different oral doses of HpCDD HABER’S RULE IS VALID FOR HpCDD TOXICITY 105 FIG. 3. Dose responses depicted at constant times to effect, (E, 15 days; Œ, 20 days; F, 30 days; }, 40 days; h, 50 days; ƒ, 60 days) FIG. 2. Correlation between dose and time (upper panel) and log (dose) and log (time) to effect (lower panel) in female Sprague-Dawley rats administered different oral doses of HpCDD worthwhile refinement, because only rats that die of the same cause are part of the same dose and time response (Table 2). The graphic presentation of the data is particularly useful, because it allows a direct comparison of these data with those reported on c 3 t 5 constant by others in previous publications. Entomologists frequently plotted the hyperbolas whereas toxicologists chose more often the log (dose)/log (time) form of presentation (Figure 2). A previous publication reported a remarkably good correlation of the 30-day log LD 50 with log (total body fat content) of TCDD in some 20 different species and strains of animals A 5.8% variability of the data can be considered acceptable in toxicology, particularly in the case of 2 overlapping doseresponses (wasting/hemorrhage). Discrimination between wasting and hemorrhage is difficult, because both are present in many animals to some degree. However, some animals die, usually suddenly without displaying the typical signs of wasting, still possessing some macroscopically identifiable abdominal fat depots and often displaying blood around the nose, but in all instances their small intestine is filled with blood. Traditional differential diagnosis between wasting, hemorrhage, and anemia in HpCDD-exposed rats has been conducted in an earlier study (Viluksela et al., 1997). This was not possible in these experiments because of the difficulty in obtaining blood from dead rats. However, our experience with about 1000 rats suggested that 25% body-weight loss is a reliable criterion for distinguishing the main cause of death between wasting and hemorrhage (Viluksela et al., 1997). Reduction of the variability of the results from 5.8 to 3.2% shows that this is a small, but FIG. 4. Time-responses depicted at constant doses to effect (}, 2.8 mg/kg; E, 3.1 mg/kg; h, 3.4 mg/kg; Œ, 3.8 mg/kg; F, 4.1 mg/kg; ƒ, 5.0 mg/kg; h, 10.0 mg/kg) 106 FIG. 5. ROZMAN Three-dimensional plot of the dose- and time-response surface. (Geyer et al., 1990). In light of the current experiment, the most likely explanation of that finding is that the more body fat a species/strain possesses, the more likely it is to survive the 30-day mark. In that sense, total body fat content is a surrogate measure of time. The sequence for starting the various dosage groups deserves some discussion. The first 3 doses represent the dose range finding whereas the other doses are self-explanatory. It should be noted that the 2.8 mg/kg dose was chosen as the last dose to be studied in order to test whether HpCDD-induced wasting was normally distributed. For that to be the case, the curvature of the dose-response had to be the same in the low as in the high dose region. Therefore, the number of rats in that dosage group had to be increased to 60 to yield an integer (5) instead of a fractional (2.5) number of expected deaths. The hypothesis of normal distribution was fully confirmed (5 of 60 rats died of wasting) with implications for population thresholds. Survivors of wasting and hemorrhage started developing anemia in all dosage groups. It remains to be seen if the c 3 t 5 constant holds also for anemia, because by the time of its development, HpCDD-treated rats had or will have excreted 30 to 50% of their body burden. Because this departure from steady state occurs according to a monotonic function, it is possible that this effect will still also occur according to c 3 t 5 constant, according to a triangular geometry (c 3 t/2 5 constant). Thus far, 9 of 30 rats died of squamous cell carcinoma of the lungs in the 2.5 mg/kg dose group, which is about twice the incidence rate reported in the Kociba et al., (1978) bioassay, using TCDD as the test compound. Correcting for relative potency by a toxic equivalency factor (TEF) of 0.007, (Viluksela et al., 1997) for HpCDD, and using the liver concentrations for HpCDD as reported by Viluksela et al., (1997) and for TCDD, those reported by Kociba et al., (1978), and as calcu- lated by Rozman et al., (1993) indicate that the relative area under the curve (rAUC) of HpCDD in this study is about twice that of the Kociba et al., (1978) experiment. The 30% lung cancer incidence in this study vs. 14% in the TCDD study suggest that c 3 t calculations may be possible across chemicals using the same mechanism of action. It is difficult to anticipate how much the various dose- and time-response analyses (Figs. 3–5) will contribute to our understanding of the c 3 t x 5 constant phenomenon, probably a great deal. It is, though, already apparent that the slope of the dose-response curve does not seem to be changing at constant times to effect even if the dose-response curve is truncated by time (Fig. 3). But the time-response curve keeps flattening (decreasing slope) as the dose decreases (Fig. 4), as if the symmetry between dose and time would be disturbed at low doses during prolonged periods of time. The most likely explanation for this phenomenon is a monotonic departure from toxicokinetic steady state. Conceptual Considerations It is interesting to note that the original statement in German about the dose response was formulated by Paracelsus in the form of a denial, which makes it the more all encompassing: “Was ist das nit gifft ist? alle ding sind gifft/und nichts ohn gifft/Allein die dosis macht das ein ding kein gift ist. [What is it that is not a poison? All things are poison/and nothing without poison /the dose alone makes that a thing is not a poison.]” This statement was then paraphrased in the first Latin edition of his famous Carinthian Trilogy as “Dosis sola fiat (facit) venenum [The dose alone makes the poison]” by an unknown translator (Deichmann et al., 1986). Paracelsus did not make explicit reference to the role of time in toxicology, although some of his writings indicate that he may have been aware of it, as in describing chronic inhalation toxicity in miners (Paracelsus, 1990). More likely, though, he was firmly embedded in the medieval time perception, which made explicit considerations of time as a variable unnecessary. Time has always been an important factor in designing toxicological experiments, yet time as an explicit variable of toxicity has been afforded very little attention. It is even more interesting that after Warren (1900) was severely criticized by Ostwald and Dernoscheck (1910) for his analogy of c 3 t 5 constant to p 3 v 5 constant of ideal gases, the entire issue was forgotten. Even though c 3 t 5 constant kept surfacing repeatedly (e.g., Druckrey and Küpfmüller, 1948; Flury and Wirth, 1934; Littlefield et al.1980; Peto et al., 1991) an analogy to thermodynamics was not contemplated again, at least not to my knowledge! Having “rediscovered” the c 3 t 5 constant concept in still another context (delayed acute oral toxicity) requires some reevaluation regarding the role of time in toxicology in a historical context. Ostwald and Dernoscheck’s (1910) analogy of toxicity to an HABER’S RULE IS VALID FOR HpCDD TOXICITY adsorption isotherm is problematic, because adsorption entails processes in far from ideal conditions. Much more reasonable is Warren’s (1900) analogy to p 3 v 5 constant for ideal gases as a comparison for ideal conditions in toxicology. Reducing the volume of a gas chamber containing a given number of molecules of an ideal gas will decrease the time for any given molecule to collide with the wall of the chamber, leading to increased pressure, which is just an attribute of the increased number of molecules per unit-volume, which is concentration. Thus c 3 t 5 constant and p 3 v 5 constant are compatible with each other if looked at mechanistically. Of course, Ostwald and Dernoscheck’s comparison of toxicity to an adsorption isotherm is much closer to the real life situation of toxicology where the most frequent finding is that c 3 t x 5 constant. These thought experiments and some discussions led to the recognition that toxicologists and thermodynamicists did everything in opposite ways. Instead of starting out with the simplest model (ideal gas in thermodynamics corresponds to ideal conditions in toxicology experiments) and building into it step by step the increasing complexity of the real world, toxicologists try to predict from one complex situation to another. In addition, time is largely ignored, although it is one of two fundamental variables of toxicology (Rozman, 1998). It is unlikely that a better understanding of biological processes at the molecular level alone will lead to improved risk predictions in toxicology, as long as the experimental designs of toxicological studies provide the wrong reference points for departure from ideal to real conditions. For example, the standard inhalation toxicity protocols (6 h/5days/week) cannot yield c 3 t 5 constant because, after 6 h of intoxication, there are up to 18 h of recovery, and on weekends there are up to 66 h of recovery, at least for compounds of short half-life. This would require at least 2 additional functions to correct for departure from steady state. The real life situation is even more complex, where departures from the ideal condition (steady state) are highly irregular. Nevertheless, it is reasonable to expect that risk prediction will be possible for even the most irregular exposure scenarios, once the reference points are estabalished as dose and time responses under ideal conditions (toxicodynamic or toxicokinetic/toxicodynamic steady state) and then to define departures of increasing complexity. In 25 years of studying the toxicity of TCDD and related compounds, the concept of c 3 t 5 constant did not emerge in any other experimental context except the 2 most recent subchronic/chronic studies, which were conducted under conditions of toxicokinetic steady state (Rozman et al., 1996; Viluksela et al., 1997, 1998). Nevertheless, a general interest in the role of time in toxicology pervaded the herein presented line of thinking for many years (Rozman, 1998; Rozman and Doull, 1998; Rozman et al., 1993, 1996). Most toxicologists are familiar with Haber’s Rule of inhalation toxicology and its applicability to some solvents. Much less reference is being made to Druckrey’s work, which extended the c 3 t concept to 107 lifetime cancer studies by oral rather than inhalation exposure. And finally, there is very little cross-referencing of the c 3 t 5 constant data generated by entomologists (e.g., Peters and Ganter, 1935; Busvine, 1938; Bliss, 1940) and those established by toxicologists. Usually, a fundamental relationship in science keeps reappearing in different contexts, as is the case with c 3 t 5 constant. Unfortunately, at the same time many apparent exceptions occur with no satisfactory explanation. Attempts at generalization fail until a commonality is detected among all experiments, as in this case among those that yielded c 3 t 5 constant. This commonality is toxicokinetic steady state and/or irreversibility of an effect, which of course can be interrelated. Anesthesia, like intravenous infusion, leads to rapid and sustained steady state for compounds of short halflife. Most anesthetics and solvents do have short half-lives, and many obey Haber’s Rule, except when measurements are taken while an adaptive process is still underway, i.e., induction of a protein. Druckrey and the ED 01 Study used feeding as a route of exposure, which yields a better steady state for compounds of intermediate half-life than for example gavage. However, the exponent x in the term of Druckrey’s general formula, increases above one rapidly as the half-life of a compound becomes shorter, because there is intermittent recovery between bouts of feeding. Most of the entomology studies were related to fumigation, which often, but not always, resulted in fairly rapid steady state. And finally HpCDD, which has a half-life of 314 days (Viluksela et al., 1997) in female rats, yields a virtual steady state for a 70-day observation period, after any route of administration, but not TCDD with a half-life of 20 days. But when TCDD’s toxicity was studied under steady state conditions, its subchronic/chronic toxicity also occurred according to c 3 t 5 constant (Rozman et al., 1993). Toxicity is a function of exposure (Ex) and exposure is a function of dose and time {T 5 f[Ex(d,t)]}. Consequences of interactions between a toxic agent and an organism at the molecular level propagate through toxicodynamic or toxicokinetic/toxicodynamic causality chains all the way to the manifestation of toxicity at the organismic level. If the recovery (consisting of adaptation, repair, and reversibility) half-life of an organism is longer than the half-life of the causative agent in the organism, then toxicodynamics becomes rate-determining (one-compartment model) or rate-limiting (multicompartment model). If the toxicokinetic half-life of the compound is longer than the recovery half-life, then toxicokinetics will be rate-determining (-limiting), in which case the toxicokinetic AUC will be identical to the toxicodynamic AUC. There are two liminal conditions for c 3 t 5 constant to emerge when the causality chain propagates through either toxicodynamic or toxicokinetic processes: Toxicodynamic. (1) In the case of no recovery (no reversibility, no repair, no adaptation), linear accumulation of injury will occur according to a triangular geometry (c 3 t/2 5 constant) following repeated doses, or according to a rectan- 108 ROZMAN gular geometry after a single dose (c 3 t 5 constant), provided that the c 3 t lifetime threshold has been exceeded. (2) After recovery (reversibility, repair, adaptation), steady state has been reached, and injury will occur according to a rectangular geometry (c 3 t 5 constant), after exceeding the c 3 t lifetime threshold. Toxicokinetic. (1) No elimination will lead to linear accumulation of a compound, and as a consequence, to accumulation of injury according to a triangular geometry (c 3 t/2 5 constant) after repeated doses, or according to rectangular geometry after a single dose (c 3 t 5 constant) above the c 3 t life time threshold. (2) After toxicokinetic (and as a consequence, toxicodynamic) steady state has been reached, injury will occur above the c 3 t lifetime threshold according to a rectangular geometry (c 3 t 5 constant). It must be kept in mind that 90 and 99% of steady state will be reached after 3.32 and 6.64 toxicodynamic or toxicokinetic/ toxicodynamic half-lives, respectively. During this time, c 3 t will be constant only if the rate-determining step is of zero order. Thus, the various (c 3 t 5 constant) scenarios represent liminal conditions. The magnitude of the c 3 t product is a function of the potency of the compound, of the susceptibility of the organism and of the deviation from the ideal conditions and will yield c 3 t x 5 constant for non-liminal conditions (Large c 3 t x product indicates either low potency, and/or lack of susceptibility and/or low exposure). In conclusion, these data and considerations of a significant body of evidence accumulated over the last 100 years suggests that c 3 t 5 constant is probably a fundamental Law of Toxicology, which can be seen only under ideal conditions. If confirmed using other classes of compounds, and in the herein described ideal conditions, then Paracelsus’ famous statement may have to be supplemented to read “Dosis et tempus fiunt (faciunt) venenum” (Dose and time together make the poison). Implications for risk assessment are that the margin of exposure (MOE) must be defined in terms of both dose and time. 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