You got the calculations right until you got to the EPA (not FDA) interpretation of acceptable vs. unacceptable levels and then it looks like you found a flaw in my assumptions. I assumed that the pool doses that exceeded the margin of exposure limits for small children were 360 ppm from Table 5 in the EPA report and note that 540*65/100 = 351, 480*74/100 = 355, 240*150/100 = 360, 5.4*5600/100 = 302 so I just used 360 ppm as the approximate limit and again this is with a margin-of-exposure of 100. Or put another way, it is at around 360 ppm Boron where the margin-of-exposure is 100 which is what EPA defines as the limit of what is acceptable vs. unacceptable.
I think I misunderstood what was meant in the table by "chemical concentration in water (mg/L)". I assumed this did not mean product concentration, but rather boron concentration. This is certainly confusing because in the text when referring to dosages of product they refer to "pool water concentration" in terms of mg/L of product (i.e. sodium tetraborate pentahydrate). The only significant hint that Table 5 may use a different measurement is the sentence before the table: "Exposure to adult and older child swimmers did not result in risks which exceed the LOC; however the higher boron concentrations in pool and spa water resulted in risks for children 7 to 10 years of age which do exceed the LOC", but that was an incorrect assumption on my part.
The "Adjusted ADD" in mg/kg/day is the effective exposure to boron and the calculation of Margin of Exposure (MOE) in that table uses 8.8 mg/kg/day Boron as the No Observed Adverse Effect (NOAE) limit as you can see from 0.134*65 = 8.71, 0.119*74 = 8.81, 0.059*150 = 8.85, 0.0016*5600 = 8.96. The 8.8 mg/kg/day is the NOAEL from the 2-year dog study and confirmed by other studies as described on page 4 of the report.
The interpretation of the "acceptable" vs. "unacceptable" amounts all depends on their assumption for how much someone drinks and the weight of the child. Let's look at 540/0.134 = 4030, 480/0.119 = 4034, 240/0.059 = 4068, 5.4/0.0016 = 3375 and let's use the inverse of 4030 or 0.000248 L/kg/day or 0.25 ml/kg/day is the implied amount drank per weight per day assuming the first column was mg/L Boron and not product. Note how the last ratio is different than the others because it is boric acid and not sodium tetraborate pentahydrate -- I should have seen that as a clue, but didn't, and I ignored the fact that the amounts listed in the first column matched what they were describing in the text -- I think I tried doing the calculations that follow below, but didn't do them correctly the first time so didn't change my assumption about what the first column meant.
If the first column was product, then converting to boron would give (540/291.29)*4*10.812 = 80.17, (480/291.29)*4*10.812 = 71.27, (240/291.29)*4*10.812 = 35.63 and (5.4/61.83)*1*10.812 = 0.9443. Using these numbers for the ratio of boron to adjusted ADD we get 80.17/0.134 = 598, 71.27/0.119 = 599, 35.63/0.059 = 604, 0.9443/0.0016 = 590. So this certainly is closer to being similar and implies that you are right about the table and I was wrong. It implies 1000/600 = 1.67 ml/kg/day.
Instead of focusing on the table, just focus on the known core facts: the 8.8 mg/kg/day NOEL and the 100 MOE. The net of these two then imply how much someone can drink. At 50 ppm Boron, I calculated 14 ml for very young children assuming a weight of 8 kilograms (17.6 pounds) which is way lower than the average 7 year old at 50 pounds. That is, (50 mg/L)*((14 ml/day)/(1000 ml/L))/((8.8 mg/kg/day)/(100 MOE)) = 7.95 kg. I think I was calculating for babies/infants where 8 kilograms would be the average 6-month old boy or 8-month old girl. And again don't forget that these amounts are for drinking every day, not one-time dosages. These calculations of drinking limits in my post are still valid since they are about the amount one can drink to get up to the NOEL limit with an MOE of 100 and aren't about the borate level that the EPA deems "acceptable".
So I think you are right that the first column in the table is product concentration and the assumption is that children are gulping larger amounts of water, namely 1.67 ml/kg/day which for a 23 kg (about 50 pounds) 7-year old would be around 1.67*23 = 38 ml or 2-1/2 tablespoons, again with a margin-of-exposure safety factor of 100.
Thanks for catching that error. I don't believe it changes the conclusions since the EPA analysis is very conservative, but might explain current dosing limits on borate products for pools of around 50 ppm Borates (ppm Boron) since (23 kg)*((8.8 mg/kg/day)/(100 MOE))/((38 ml/day)/(1000 ml/L)) = 53 mg/L.
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