Replace the NOAEL and LOAEL with the BMDL01 and BMDL10

Although benchmark-dose methodology has existed for more than 20 years, benchmark doses (BMDs) still have not fully supplanted the no-observed-adverse-effect level (NOAEL) and lowest-observed-adverse-effect level (LOAEL) as points of departure from the experimental dose-response range for setting acceptable exposure levels of toxic substances. Among the issues involved in replacing the NOAEL (LOAEL) with a BMD are (1) which added risk level(s) above background risk should be targeted as benchmark responses (BMRs), (2) whether to apply the BMD methodology to both carcinogenic and noncarcinogenic toxic effects, and (3) how to model continuous health effects that aren't observed in a natural risk-based context like dichotomous health effects. This paper addresses these issues and recommends specific BMDs to replace the NOAEL and LOAEL.