“…Mode of action (MOA) is increasingly being considered in the risk assessment of pesticides� During the past decade, the International Life Sciences Institute (ILSI) and the International Programme on Chemical Safety (IPCS) of the World Health Organization (WHO) have been evolving a framework for the analysis of mode of action for rodent toxicity and carcinogenicity findings along with assessment of their human relevance (Sonich-Mullin et al�, 2001;Meek et al�, 2003;Seed et al�, 2005;Boobis et al�, 2006Boobis et al�, , 2008� Numerous case studies have been published illustrating the applicability of the framework for genotoxic and nongenotoxic cancer modes of action and for cancer and noncancer endpoints� Mode of action analysis has been incorporated into the risk assessment guidelines of various regulatory agencies, including the US Environmental Protection Agency (US EPA, 2005)� Folpet and captan are used for their fungicidal properties in both industrial and agricultural products� Their structures are shown in Figure 1 along with their reaction with thiols� Both compounds have Reregistration Eligibility Decisions (REDs) issued (US EPA 1999a, 1999b as well as subsequent reviews (US EPA 2003, 2004a, 2004b) that included the reclassification of captan from "B2" (probable human carcinogen) to "not likely" at dietary exposures expected from agricultural use (US EPA, 2004a;Gordon, 2007)� The major tumor finding from captan bioassays was gastrointestinal adenomas and adenocarcinomas in mice, primarily in the duodenum� By contrast, there was no carcinogenic effect of captan in rats� The 2004 cancer reclassification was based on the 1999 proposed Carcinogenic Risk Assessment guidelines (US EPA, 1999c) that were finalized in 2005 (US EPA, 2005)� Folpet, chemically and biologically similar to captan, has also been evaluated in rodent carcinogenicity bioassays and has a similar pattern of tumor development, that is, gastrointestinal tumors in mice and the absence of treatmentrelated tumors in rats� Studies evaluating the early stages of effects in the gastrointestinal tract support analysis of the mode of action� Folpet provides an example of how the application of the ILSI/IPCS mode of action and human relevance framework can be applied to tumors in assessing possible carcinogenic risk to humans� Folpet previously was considered by EPA a genotoxic carcinogen, like captan, and was considered a carcinogen in mice and rats (Quest et al�, 1993)� Given the information available concerning mode of action, assessment of human relevance and the precedent setting case of captan, folpet today would likely be classified as a nongenotoxic, threshold-based carcinogen, with carcinogenicity only in mice� We describe below the basis for concluding that the rat bioassays are negative; this has also been the conclusion of Joint Food and Agriculture Organization of the United Nations (FAO/WHO) Meeting on Pesticide Residues (JMPR) (FAO/WHO, 1996) and European Food Safety Au...…”