“…For the duodenal tumors induced in mice by folpet, the mode of action involves irritation-related cytotoxicity with consequent cellular regeneration ultimately leading to the development of tumors� The critical key event involves consumption of sufficiently high levels of folpet that yield a cytotoxic concentration of folpet and its degradation product, thiophosgene� Combined, these chemicals can cause cytotoxicity in the duodenum (Table 6)� In the stomach and duodenum there is cytotoxicity from the direct reaction of folpet with cellular components containing thiol groups as well as from the highly reactive thiophosgene, a hydrolysis product of folpet, which reacts with thiols as well as other cellular constituents (see Figures 1 and 2)� Folpet itself, like captan (Wilkinson et al�, 2004), is reactive with thiol groups, which generates thiophosgene (Figure 1)� However, thiophosgene is also reactive with thiol groups (Figure 2), with a half-life of less than 1 s (0�6 s in human blood)� Thiophosgene, thus, is generated either by the reaction of folpet with thiol groups or following hydrolysis of folpet� Direct interaction of folpet with thiol groups is the primary source of the thiophosgene� The hydrolysis of folpet to thiophosgene is highly pH dependent� The reaction occurs readily at neutral to alkaline pH but significantly less at low pH� Because of their marked reactivity, folpet and thiophosgene will react rapidly with thiol groups and not reach DNA or DNA-related targets (e�g�, histones) Liu and Fishbein, 1967;Lukens, 1966;Lukens et al�, 1965;Siegel, 1971aSiegel, , 1971bBernard and Gordon, 2000)� This is highlighted by a pair of key in vivo studies that show folpet and captan do not induce genotoxicity, as evidenced by the lack of increased nuclear aberrations in the tumor target site, the duodenum (Chidiac and Goldberg, 1987;Gudi and Krsmanovic, 2001)� Thus, DNA damage is highly unlikely and not detected in studies designed to assess this effect at the target tissue in vivo (Arce et al�, 2010)�…”