2 The steps in the human health risk assessment
2.1 Hazard characterization
2.1.1 Establishing guidance levels (DNELs and DMELs) for the general public
2.1.1.1 Derivation of guidance levels
The derivation of guidance levels involves the following steps:
-
Hazard identification;
-
Hazard characterization;
As part of the hazard identification the type and nature of adverse health effects to
humans are identified. The data may consist of information from epidemiological studies
and animal-based toxicology studies.
The hazard characterization includes establishing guidance levels (DNELs and DMELs).
The guidance levels are levels, for chemicals with a threshold effect, below which no
adverse health effects to humans are expected to occur.
However, for chemicals with a non-threshold effect, such as genotoxic carcinogens, where
no lower safe limit exists, the guidance levels are associated with a low, possibly
hypothetical, acceptable risk.
2.1.1.2 Dose descriptor
For all chemicals, an effect level, or reference dose, linked to potential adverse
effects has to be defined. The Benchmark Dose (BMD) approach is regarded to represent a
scientifically more advanced method compared to the NOAEL approach for deriving a
reference dose (sometimes referred to as point-of-departure (EFSA, 2017)). The
BMD10 is defined as the dose for a predetermined level of response, 10%
increase or decrease, compared with the background response. It is recommended to use
the lower bound of a BMD10, i.e. the BMDL10 (US EPA, 2012).
2.1.1.3 Assessment factor or adjustment factor
When results from animal-based studies are extrapolated to the general public, one or
more assessment factors are used to reduce the likelihood that the actual risks to
humans are underestimated. When results from human are used, adjustment factors may be
used to account for human variability.
2.1.2 Guidance values for the general public (threshold effects)
Guidance values based on epidemiological studies, when available, are always preferred
(WHO, 2000), and may be retrieved from internationally recognized bodies. These include
guidance values established by, for example, JECFA or EFSA for food contaminants, such
as TDI, and by WHO for chemicals in drinking water.
Guideline values for chemicals in drinking-water have been established for chemicals
that cause adverse health effects after prolonged periods of time. A guideline value
normally represents the concentration of a chemical that does not result in any
significant risk to health over a lifetime of consumption. The guideline values assume a
water consumption of 2 litres per day, and a body weight of 60 kg.
A number of provisional guideline values have, however, been established based on the
practical level of treatment performance or analytical achievability. In these cases,
the guideline value is higher than the calculated health-based value.
Table 1: Summary of examples of guidance values used for the general public
| Type of outcome
|
Term (units)
|
Abbreviation
|
Definition
|
| Non-cancer, including laboratory animal carcinogens not
relevant to humans
|
Tolerable daily intake (mg/kg bw/day)
|
TDI
|
An estimate of the amount of a substance in air, food,
soil or drinking-water that can be taken in daily, weekly or monthly per
unit body weight over a lifetime without appreciable health risk.
|
| Provisional tolerable weekly intake (mg/kg bw/week)
|
PTWI
|
| Provisional tolerable monthly intake (mg/kg bw/month)
|
PTMI
|
| Derived No Effect Level (mg/kg bw/day)
|
DNEL
|
2.1.3 Guidance values for the general public (non-threshold effects)
2.1.3.1 Approaches to risk assessment
Carcinogens can have a threshold or non-threshold mode of action. As a general rule, a
risk for the general public from secondary exposure to a non-threshold carcinogenic
substance is unacceptable. When it comes to the threshold carcinogens, these can be
assessed by using a DNEL approach. In the case of the non-threshold carcinogens (i.e.
with mutagenic potential), a different approach to risk assessment is recommended. In
this guideline, the lifetime excess cancer risk level of 10-5 is used where
possible (in accordance with the WHO Drinking Water Methodology, (WHO, 2001)).
2.1.3.2 Derived Minimal Effect Level
Calculation of an exposure level corresponding to a defined low risk, a Derived Minimal
Effect Level (DMEL) is possible based on a semi quantitative approach. In contrast to a
DNEL, a DMEL does not represent a "safe" level of exposure. It is a risk related
reference value that could be used to better target risk management measures.
2.1.3.3 The large assessment factor approach
The "large assessment factor" approach results in DMEL values represents a low concern
from a public health point of view. The basis for this assessment factor is that for
substances that are both genotoxic and carcinogenic, an MOE of 10,000 or higher, based
on a BMDL10 from an animal study, is regarded to be of low concern (EFSA,
2017).
When a BMDL10 from an animal study (oral rat carcinogenicity study) is used
the assessment factors shown in table 2 should be used.
Table 2: Default assessment factors in the "large assessment factor approach"
(modified from ECHA, 2012)
| Assessment factor
|
Default value systemic tumours
|
| Interspecies
|
10
|
| Intraspecies
|
10
|
| Nature of the carcinogenic process
|
10
|
| The point of comparison
|
10
|
| Total assessment factor
|
10,000
|
(Equation 1)
A DMEL derived according to this approach represents an excess cancer risk of 10-5.
2.1.3.4 The slope factor approach
A slope factor is an estimate of the life-time cancer risk associated with a unit dose
of a chemical through ingestion (or inhalation). The slope factor is defined as
increased cancer risk from lifetime exposure to a substance by ingestion (or
inhalation). It is expressed as an estimate of cancer risk associated with a unit
concentration (mg/kg bw/d) or risk per mg/kg bw/d (US EPA, 2005). The slope factor may
be used to derive the dose (mg/kg bw/d) associated with cancer at a specified risk
level, for instance 10-5 (or 1 in 100 000). This dose may then be used as a
DMEL.
2.1.3.5 Drinking-water guideline values
Drinking-water guideline values are normally determined using a mathematical model (the
linearised multistage model) for chemicals considered to be genotoxic carcinogens. These
guideline values are presented as concentrations in drinking-water associated with an
estimated upper-bound excess lifetime cancer risk of 10-5.
2.2 Exposure assessment
2.2.1 How and where humans may be exposed to EGCS discharge water
Humans may be exposed to EGCS discharge water when swimming in the water where the EGCS
discharge water has been discharged, or when consuming seafood that has been caught in
the vicinity of the area where the EGCS discharge water has been discharged. In some
areas of the world, desalinated seawater is used as drinking water which will add
another way of probable exposure. In this guideline, the aggregate exposure approach, as
defined by WHO/IPCS (WHO/IPCS, 2009), is applied, that is the combined exposure
applicable to each scenario. The term "aggregated exposure" (or "combined exposure"), as
defined by the WHO/IPCS, takes into account all relevant pathways (e.g. food, water and
residential uses) as well as all relevant routes (oral, dermal and inhalation).
2.2.2 Human exposure scenario
The exposure assessment is carried out through an evaluation of different exposure
scenarios. An exposure scenario is a set of information and/or assumptions that
describes the situations associated with the potential exposure.
2.2.3 Situations in which the general public might be exposed to EGCS discharge water
2.2.3.1 Exposure scenarios for the general public
Indirect exposure of humans via the environment associated with EGCS discharge water may
occur by consumption of seafood and swimming in the receiving water. As a general
principle, consumer exposure is normally assessed as being chronic and thus taking place
throughout the whole lifetime in order to protect the most vulnerable population groups.
The following situations, as shown in table 3, have been identified as likely exposure
scenarios for the general public, and have been regarded as a worst-case exposure.
As the human activities listed in table 3 are not performed near the discharge points
for MAMPEC calculations, the maximum PECs in the surroundings should be used as
representative concentration in a worst-case exposure.
Table 3: Summary of exposure scenarios for the general public
| Situations in which the general public
may be exposed to EGCS discharge water containing
chemicals
|
| Situation
|
Exposure
|
Duration/quantity
|
| Recreational activities in the sea
|
Inhalation of chemicals partitioning into the air above the
sea
|
2 events of 0.5 hours/day
|
| Dermal exposure to chemicals whilst swimming in the sea
|
2 events of 0.5 hours/day
|
| Swallowing of seawater contaminated with EGCS discharge water
|
2 events of 0.5 hours/day
|
| Eatingseafood exposed to EGCS discharge water
|
Oral consumption
|
Once or twice/day equivalent to 0.107 kg/day
|
| Drinkingwater preparedfrom receiving water that may have
been contaminated by the EGCS discharge water
|
Inhalation of chemicals volatilising from drinking water while
showering
|
0.75 hours/day
|
| Dermal exposure to chemicals in drinking water while
showering
|
0.75 hours/day
|
| Ingestion exposure to chemicals in drinking water
|
Daily total drinking water intake of 2 L/day
|
| Aggregated exposure (through swimming,
consumption of seafood and using drinking water)
|
A number of assumptions are being used in the human exposure scenarios for
the general public. These assumptions are listed in table 4. In all scenarios, default
parameters leading to worst-case assessment are applied. Accordingly, the body surface
area of men is assumed, but the body weight of women (60 kg) is applied. The whole-body
surface area for men is 1.94 m2. One parameter, ingestion rate of water while
swimming, is taken from the Swimodel (US EPA, 2003).
Table 4: Summary of physiological parameters in human exposure scenarios for the
general public
| Parameter
|
Value
|
Reference
|
| Body weight
|
60 kg
|
WHO (2017)
|
| Whole body, surface area
|
1.94 m2
|
US EPA (1997)
|
| Ventilation rate (light activity)
|
1.25 m3/h
|
ECHA (2012)
|
| Ingestion rate of water while swimming
|
0.025 L/h
|
Swimodel, US EPA (2003)
|
| Ingestion rate of drinking water
|
2 L/d
|
WHO (2017)
|
| Showering
|
0.75 h/d
|
US EPA (2011)
|
| Quantity of fish consumed
|
0.107 kg/d
|
AIST, Japan (2007)
|
| Temperature
|
293 K
|
GESAMP assumption
|
| Dilution factor, swimming
|
100
|
EUSES (2016)
|
| Reduction rate of chemicals through the desalination process for
making up drinking water
|
10
|
Average reduction rate of chemicals through the RO treatment: 90%
(Smol, M. and Włodarczyk-Makuła, M., 2017)
|
2.2.3.2 Recreational activities (swimming) in the sea
-
.1 Inhalation of chemicals partitioning into the air above the sea
Exposure in this scenario is through inhalation of air above the sea while
swimming. The concentration of chemicals in the air may be calculated while using
the Henry's law constant as described below.
The worst concentration of chemicals in the air may theoretically be calculated
using the Henry's law constant. This physical law states that, the mass of gas
dissolved by a given volume of solvent, is proportional to the pressure of the gas
with which it is in equilibrium. The relative constant quantifies the partitioning
of chemicals between the aqueous phase and the gas phase such as rivers, lakes and
seas with respect to the atmosphere (gas phase). While making use of the
concentration in the water phase, the concentration in the air phase is calculated
accordingly:
(Equation 2)
-
| Cair
|
= concentration in air (mg/m3);
|
| H
|
= Henry's law constant (Pa m3/mole);
|
| R
|
= gas constant (8.314 Pa m3/mole K);
|
| T
|
= absolute temperature (K) (default =
293 K); and
|
| Cwater
|
= concentration in the water, i.e.
maximum PECMAMPEC in surroundings (μg/L).
|
The concentration in water is the maximum predicted environmental concentration
(PEC) value in surroundings as calculated by MAMPEC, and taking into account a
dilution factor of 100 (due to wind, turbulence and insufficient time for the
chemical to reach equilibrium) (EUSES, 2016). The inhaled dose may be estimated
using the equation below, while taking into account various assumptions (number of
swims, etc.).
(Equation 3)
where:
| DoseInh
|
= inhalation intake of chemical during
swimming (μg/kg bw/d);
|
| Cair
|
= concentration in air (mg/m3);
|
| VR
|
= ventilation rate – light activity
assumed (1.25 m3/h);
|
| n
|
= number of swims per day (2/d);
|
| Durswim
|
= duration of each swim (0.5 h);
|
| Bioinh
|
= fraction of chemical absorbed through
the lungs (default = 1); and
|
| BW
|
= body weight (default = 60 kg).
|
-
.2 Dermal exposure to chemicals while swimming in the sea
Option 1.
(Equation 4.1)
where:
| Doseder
|
= dermal uptake per day during swimming
(μg/kg bw/d);
|
| Cwater
|
= concentration in the water, i.e.
maximum PECMAMPEC in surroundings (μg/L);
|
| Kp
|
= dermal permeability coefficient
(cm/h);
|
| Durswim
|
= duration of each swim (0.5 h);
|
| n
|
= number of swims per day (2/d);
|
| Askin
|
= surface area of whole body being
exposed to water (1.94 m2);
|
| Bioder
|
= bioavailability for dermal intake
(default = 1); and
|
| BW
|
= body weight (60 kg).
|
Option 2
-
If the Kp value is unknown, the following equation may be used as a
conservative approach (ECHA, 2016),
(Equation 4.2)
where:
| Doseder
|
= dermal uptake per day during swimming
(μg/kg bw/d);
|
| Cwater
|
= concentration in the water, i.e.
maximum PECMAMPEC in surroundings (μg/L);
|
| THder
|
= thickness of the product
layer on the skin (0.0001 m);
|
| N
|
= number of swims per day (2/d);
|
| Askin
|
= surface area of whole body being
exposed to water (1.94 m2);
|
| Bioder
|
= bioavailability for dermal intake
(default = 1); and
|
| BW
|
= body weight (default = 60 kg).
|
-
.3 Swallowing of water contaminated with EGCS discharge water
The oral uptake via swimming is calculated according to the following:
(Equation 5)
where:
| DoseOral
|
= amount of chemical swallowed (μg/kg
bw/d);
|
| Cwater
|
= concentration in the water, i.e.
maximum PECMAMPEC in surroundings (μg/L);
|
| IRswim
|
= ingestion rate of water while swimming
(0.025 L/h);
|
| N
|
= number of swims per day (2/d);
|
| Durswim
|
= duration of each swim (0.5 h);
|
| Biooral
|
= bioavailability for oral intake
(default = 1); and
|
| BW
|
= body weight (default = 60 kg).
|
2.2.3.3 Eating seafood exposed to EGCS discharge water
The concentration of chemicals in the seafood that is being consumed is calculated in
this way:
Cfish = BCF · Cwater
(Equation 6)
where:
| Cfish
|
= concentration in fish (μg/kg);
|
| BCF
|
= bioconcentration factor (L/kg); and
|
| Cwater
|
= concentration in the water, i.e. maximum
PECMAMPEC in surroundings (μg/L);
|
The calculation of concentrations in seafood has to be carried out for all chemicals.
The cut-off value for the bioconcentration factor as described for the environmental
risk assessment (paragraph 6.6.3) is not applicable in the risk assessment for human
health. Making the assumption that people in the area only consume fish that is being
caught locally (worst-case scenario), the daily intake may be calculated in the
following way:
(Equation 7)
where:
| Dosefish
|
= uptake of chemical from eating fish (μg/kg
bw/d);
|
| QFC
|
= quantity of fish consumed/day (= 0.107 kg/d
(AIST, Japan (2007)));
|
| Cfish
|
= maximum concentration of chemical in fish
(μg/kg);
|
| Biooral
|
= bioavailability for oral intake (default =
1); and
|
| BW
|
= body weight (default = 60 kg).
|
2.2.3.4 Drinking water made from receiving water that may have been contaminated by EGCS
discharge water:
-
.1 Inhalation of chemicals volatilisation from drinking water while showering
Exposure in this scenario is through inhalation of chemicals volatilising from
drinking water while showering. The concentration of chemicals in the air may be
calculated while using the Henry's law constant as already described in equation
1. The concentration in the drinking water is the same as in the scenario 2.2.3.2
and 2.2.3.3, while also taking into consideration a removal ratio of 10 in Reverse
Osmosis (RO) desalination process (Smol, M. and Włodarczyk-Makuła, M., 2017),
based on the concentration in the receiving water (i.e. the maximum PECs in the
surroundings of MAMPEC calculation).
(Equation 8)
where:
| Cair
|
= concentration in air (mg/m3);
|
| H
|
= Henry's law constant (Pa m3/mole);
|
| R
|
= gas constant (8.314 Pa m3/mole K);
|
| T
|
= absolute temperature (K) (default =
293 K); and
|
| CDW
|
= concentration in the drinking water,
i.e. maximum PECMAMPEC in surroundings (μg/L)·0.9 (μg/L).
|
The inhaled dose, while showering, may be estimated using the equation below,
while taking into account various assumptions,
(Equation 9)
where:
| DoseInh
|
= inhalation intake of chemical during
swimming (μg/kg bw/d);
|
| Cair
|
= concentration in air (mg/m3);
|
| VR
|
= ventilation rate – light activity
assumed (1.25 m3/h);
|
| N
|
= number of showers per day (1/d);
|
| Durshow
|
= duration of each shower (0.75 h);
|
| Bioinh
|
= fraction of chemical absorbed through
the lungs (default = 1); and
|
| BW
|
= body weight (default = 60 kg).
|
-
.2 Dermal exposure to chemicals while showering
Option 1
Exposure in this scenario is via dermal uptake of chemicals when taking a shower,
and where the dermal permeability coefficient (Kp) is known, is calculated using
the following equation,
(Equation 10.1)
where:
| Doseder
|
= dermal uptake per day during swimming
(μg/kg bw/d);
|
| CDW
|
= concentration in the drinking water,
i.e. maximum PECMAMPEC in surroundings (μg/L)·0.9 (μg/L);
|
| Kp
|
= dermal permeability coefficient
(cm/h);
|
| Durshow
|
= duration of each shower (0.75 h);
|
| N
|
= number of showers per day (1/d);
|
| Askin
|
= surface area of whole body being
exposed to water (1.94 m2);
|
| Bioder
|
= bioavailability for dermal intake
(default = 1); and
|
| BW
|
= body weight (60 kg).
|
Option 2
If the Kp value is unknown, the following equation may be used as a
conservative approach,
(Equation 10.2)
where:
| Doseder
|
= dermal uptake per day during swimming
(μg/kg bw/d);
|
| CDW
|
= concentration in the drinking water,
i.e. maximum PECMAMPEC in surroundings (μg/L)·0.9 (μg/L);
|
| THder
|
= thickness of the product layer on the
skin (0.0001 m);
|
| N
|
= number of showers per day (1/d);
|
| Askin
|
= surface area of whole body being
exposed to water (1.94 m2);
|
| Bioder
|
= bioavailability for dermal intake
(default = 1); and
|
| BW
|
= body weight (default = 60 kg).
|
-
.3 Ingestion exposure to chemicals in drinking water
The oral uptake via drinking water is calculated according to the following,
(Equation 11)
where:
| DoseOral
|
= amount of chemical swallowed (μg/kg
bw/d);
|
| CDW
|
= concentration in the drinking water.
i.e. maximum PECMAMPEC in surroundings (μg/L)·0.9 (μg/L);
|
| IRdrink
|
= ingestion rate of drinking water (2
L/d);
|
| Biooral
|
= bioavailability for oral intake
(default = 1); and
|
| BW
|
= body weight (default = 60 kg).
|
2.2.4 Concluding remarks
It should be noted that while the above situations have been identified as typical
worst-case exposure scenarios, it is recognized that there will be other situations when
exposure of the general public may be greater or less, and consideration should be given
to such situations. In addition, the consumer exposure (general public) is normally
assessed as chronic/lifetime risk in order to protect the most vulnerable population
groups.
2.3 Risk characterization and acceptance criteria
2.3.1 General approach
The Risk Characterization Ratios (RCR) compares the exposure estimates to various DNELs
or DMELs. The RCR is calculated according to the following formulae:
-
(Equation 12)
Or
-
(Equation 13)
In both cases, RCR should be used as acceptance criteria. If the RCR < 1, the
exposure will lead to no unacceptable risk. However, risks are regarded to be controlled
when the estimated exposure levels exceed the DNEL and/or the DMEL, that is, if the RCR
≥ 1.
2.3.2 Health risks for the general public
In the three scenarios applicable for the general public, swimming in seawater
contaminated with EGCS discharge water, ingestion of seafood which has been exposed to
EGCS discharge water and ingestion of drinking water prepared from receiving water that
may have been contaminated by the EGCS discharge water, are taken into consideration.
Aggregated exposure (through swimming, consumption of seafood and drinking water
prepared from receiving water that may have been contaminated by the EGCS discharge
water), that is the combined exposure applicable to each scenario, is estimated.
The total amount of chemicals that is absorbed as a result of the exposure to the
general public, whilst swimming in the sea, eating fish and being exposed to drinking
water through showering and drinking water consumption, may be summarised as in table 5.
Table 5: General public scenario – DNEL approach

The risk-related reference value (DMEL) may be used to calculate an
indicative RCR regarding potential cancer risk. DMELs can be used to estimate a risk
dose based on the probability of increased cancer incidence over a lifetime
(10-5) for the general public (table 6).
Table 6: General public scenario – DMEL approach
| Chemical name
|
Aggregated exposure (μg/kg bw/d)
|
DMEL (μg/kg bw/d)
|
Indicative RCR
|
| A
|
|
|
|
| B
|
|
|
|
| C
|
|
|
|
2.3.3 Mixture toxicity (including dose addition approach)
EGCS discharge water frequently contains mixtures of several chemicals which lead
similar mechanism in human systems. One possible way to deal with this situation is to
adopt an established international risk assessment approach (known as "grouping" or
"dose addition"; Kortenkamp, et al., 2009), which entails a summation of the Risk
Characterization Ratios (RCRs) of all substances with recognized carcinogenic potential.
This approach had, for example, been used previously for carcinogens by the US EPA (US
EPA, 1989), where it is based on the assumption that for carcinogens no dose threshold
exists, and that the dose-response function is therefore essentially linear. Thus, if
the EGCS discharge water contains two or more chemicals with the same toxicological
effect, these could be evaluated as an "assessment group". The RCR for an assessment
group is calculated by the addition of all RCRs of the individual components,
-
(Equation 14)
where:
RCRn = the Risk Characterization Ratios shown in table 5 or table 6.
For the group RCR, the same conclusions apply as described above, that is, if the RCR
< 1 using the RCRs in table 6, the exposure is deemed to represent no unacceptable
risk. If still an unacceptable risk is identified, further refinement of the exposure
assessment and/or the assessment factors might be performed giving special attention to
route-specific contributions and additional RMM.
References
AIST (2007). Japanese Exposure Factors Handbook. National Institute of Advanced
Industrial Science and Technology.
ECHA (2012). Guidance on information requirements and chemical safety assessment.
Chapter R.8: Characterisation of dose (concentration)-response for human health. Version
2.1 November 2012.
ECHA (2016). Guidance on Information Requirements and Chemical Safety Assessment.
Chapter R.15: Consumer exposure assessment. Version 3.0 July 2016.
EFSA (2017). Guidance. Update: use of the benchmark dose approach in risk assessment.
EFSA Journal, 15 (1), 4658.
EUSES (2016). The European Union System for the Evaluation of Substances (EUSES).
Version 2.1. European Chemicals Agency (ECHA), 2016.
Kortenkamp. A.; Backhaus, T.; and Faust, M. (2009). State of the art report on mixture
toxicity. Final report.
Smol, M.; and Włodarczyk-Makuła, M. (2017). The effectiveness in the removal of PAHs
from aqueous solutions in physical and chemical processes: a review. Polycyclic Aromatic
Compounds, 37(4), 292-313.
US EPA (1989). Risk Assessment – Guidance for superfund. Vol 1. Human Health Evaluation
Manual. Part A.
US EPA (1997). Exposure Factors Handbook Vol. I-III. (Update to Exposure Factors
Handbook EPA/600/8-89/043 – May 1989). US Environmental Protection Agency (EPA), Office
of Research and Development, EPA/600/P-95/002Fa, Washington, DC.
US EPA (2003). User's Manual Swimmer Exposure Assessment Model (SWIMODEL) Version 3.0.
US EPA, Office of Pesticide Programs, Antimicrobials Division, November 2003.
US EPA (2005). Guidelines for Carcinogen Risk Assessment. Available at:
https://www.epa.gov/sites/production/files/2013-09/documents/cancer_guidelines_final_3-25-05.pdf
US EPA (2011). Exposure Factors Handbook: 2011 Edition. US Environmental Protection
Agency (EPA), Office of Research and Development, EPA/600/R-09/052F, Washington, DC.
US EPA (2012). Benchmark Dose Technical Guidance. Risk Assessment Forum, US
Environmental Protection Agency (EPA), EPA/100/R-12/001, Washington, DC.
WHO (2000). Working Group report on Evaluation and use of epidemiological evidence for
environmental health risk assessment: WHO Guideline Document Environmental Health
Perspective, 108, 997-1002.
WHO (2001). Water Quality Guidelines, Standards and Health Assessment of risk and risk
management for water-related infectious disease. Fewtrell, L. and Bartram, J. (Eds)
WHO/IPCS (2009). Harmonisation Project Document 7. Assessment of combined exposures to
multiple chemicals: report of a WHO/IPCS international workshop on aggregate/cumulative
risk assessment.
WHO (2017). Guidelines for drinking-water quality, 4th edition, incorporating the 1st
addendum.