What reference levels should exposures be compared to?

Although FDA appears to agree that reference air concentrations derived for the protection of the non-occupationally exposed, general population should be employed for the assessment of potential risks posed by amalgam

From FDA Final Rule: “These reference values… are considered to represent chronic or lifetime inhalation exposures that are free from adverse health outcomes and protective of human health for all individuals, including potentially sensitive populations such as children prenatally or postnatally exposed to mercury vapour.”

the only comparisons the FDA presents relate to effects and exposure levels reported in occupational studies of adults.

There was no attempt to accurately quantify exposure to mercury vapor arising from the use of dental amalgam in the general US population, nor to compare those exposure levels to the reference air concentration (RfC) published by the US EPA (EPA, 1995) or the minimal risk level (MRL) published by the ATSDR (1999), both reference levels established for the protection of that non-occupationally exposed U.S. general population.

Health Canada (1995), on the other hand, directly compared mercury vapor exposure from dental amalgam to such a reference exposure level specifically derived for the protection of the general population.

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