Delaney still the best protection.

The December 1995 artide on pesticides in food (EHP 103:1082) misstates the basic issues around the Delaney Clause and misses the point. While this federal regulation has its limitations, such as it does not address all food types such as raw fruits and vegetables (and these limitations should be corrected), contrary to what the article says, Delaney offers the best possible protection of public health, induding children who are more susceptible and vulnerable, because it says that no amount of a carcinogen in food is acceptable. There can be no better protection than not allowing any carcinogen in food regardless of who eats it. All the alternatives to Delaney incorporate some form of risk assessment which will attempt to define some level of "acceptable risk." These are the approaches that will suffer many of the problems described in the report, not Delaney. Delaney needs fixing to expand its reach. It should not be replaced by risk assessment approaches that will be more subjective , more vulnerable to assumptions and uncertainties, and ultimately less protective of public health not only for children, but for everyone. The article by 0vreb0 et al. in the September 1995 issue of EHP(103:838-843) is a valuable contribution to environmental health efforts in eastern Europe and will no doubt serve as a benchmark in the future. We do, however, have concerns about the poor correlation between pyrene in air and 1-hydroxypyrene in urine found by 0vreb0 et al., which led them to conclude that pyrene in air is not a strong predictor of 1-hydroxypyrene. The basis for collection of polycyclic aromatic hydrocarbons (PAHs) using NIOSH method 5515 (1) assumes PAHs up to fluoranthene are partially retained on the filter substrate and all higher PAHs are 100% retained. Hence, the authors chose to collect only the particulate fraction ofworkplace and ambient air. It is interesting to note the absence of method validation data in NIOSH method 5515 but its indusion in NIOSH method 5506 (X. The difference in these two methods is solely the analytical method of analysis: gas chromatography in 5515 and HPLC in 5506. Inspection of measurement precision in NIOSH 5506 using spiked sampling trains in a laboratory atmosphere indicates PAHs ranging from naphthalene to fluoran-thene exhibited significant volatilization and PAHs from benz[a]anthracene to inde-no[1,2,3-calpyrene showed no volatilization. The data for pyrene were not determined. Work by Kirton (3) has shown four-ring PAHs incompletely retained on …