“…The lack of effect on the glandular stomach mucosa is consistent with numerous other highly reactive substances administered directly into the gastric lumen by gavage, which also do not produce toxicity in the glandular stomach (see below)� The forestomach squamous mucosa appears to be much more susceptible to chemical reactivity whereas the glandular stomach mucosa is highly resistant� This may be due to the presence of a thick mucus layer on the glandular stomach as well as its normal, physiologic resistance to the extremely low pH (pH of 1�0-2�0) to which it is naturally exposed� Furthermore, folpet's hydrolytic stability increases at low pH, resulting in limited evolution of thiophosgene� In the forestomach, the pH of the contents approximates pH of 5 (Procter et al�, 2007;McConnell et al�, 2009); at this pH hydrolysis would increase with the concurrent generation of thiophosgene� As long as the folpet is present in the diet at sufficiently high doses, cytotoxicity of the duodenum will result� For folpet, the cytotoxicity is clearly a threshold phenomenon and is reversible� The necessity for continued exposure to folpet to produce cytotoxicity and the continued increased proliferation was noted in a reversibility study (Waterson, 1995)� Following 28 days of exposure, an additional 28 days without folpet administration resulted in complete recovery of the duodenal lesions� This is quite typical for chemicals having a cytotoxic mode of action� It is also typical for duodenal disorders involving blunting (hypertrophy) of the villi and chronic inflammation, in rodents or in humans (Noffsinger and Waxman, 2007)� Once the offending stimulus is removed, the villi are able to return to normal, usually within a matter of days (Potten and Loeffler, 1990;)� With this cytotoxicity in mice, there is consequent regenerative proliferation (Figure 7)� This is seen in the duodenal mucosa as measured both by an increase in bromodeoxyuridine (BrdU) or proliferating cell nuclear antigen (PCNA) labeling index and widening of the length of the stem cell portion of the small intestinal crypts, indicating an expansion of the target cell population that can evolve into tumors (Milburn, 1997;Waterson, 1995)� It is only the stem cell population of the small intestine that can actually evolve into a malignant tumor (Potten and Loeffler, 1990;)� Expansion of this stem cell population in the crypts represents an increase in the number of potential cells that can develop the spontaneous genetic errors that are necessary for the development of malignancy� This combination of an expanded number of cells with a higher proliferative rate than normal provides an ample background for which a tumorigenic response can evolve (Cohen and Ellwein, 1990;Greenfield et al�, 1984;Knudson, 1971;Moolgavkar and Knudson, 1981)� A similar process appears to be occurring in the mouse forestomach (see below)� It is also noted that there is a low incidence of spontaneously transformed cells resident in the crypt compartment, based on the incidence of duodenal tumors found in control mi...…”