In the two-year carcinogenicity study conducted by the National Toxicology Program (NTP) and reported in 1999, ethyl benzene administered by inhalation to Fischer 344 rats was associated with an increase in renal tubule tumors in males after standard evaluation of a single section of each rat's kidney, and in both males and females after evaluation of step-sectioned kidney. In the present study, the kidneys of all rats in the NTP bioassay were histopathologically reevaluated with the purpose of attempting to define a mode of action underlying the development of the renal tumors. In the reevaluation, the increases in renal tubule tumor incidence in the high-dose groups exposed to 750 ppm were confirmed, as well as increases in the precursor lesion, atypical tubule hyperplasia (ATH). The vast majority of the proliferative lesions were of basophilic type and, apart from three carcinomas in the high-dose males, either small adenomas or foci of ATH. There was also a marked exacerbation by the chemical of chronic progressive nephropathy (CPN), an age-related spontaneous disease involving both degenerative and regenerative components, in the high-dose males exposed to 750 ppm of ethyl benzene (68% of high-dose males with end-stage CPN versus 12% of control males), and a modest exacerbation in the high-dose females (8% of high dose versus 0% of controls). Almost all of the basophilic tumors occurred in rats with advanced, usually end-stage, CPN, and they were located in areas of parenchyma involved in the CPN disease process. Statistical analysis of the proliferative lesion and CPN data revealed a highly significant correlation between ATH/renal tumor incidence and end-stage CPN, and adjusting for end-stage CPN removed any statistically significant difference in renal tumor incidence between treated groups and controls. Careful examination of renal tubules revealed no evidence of renal tubule injury or increased mitotic activity that would support sustained cytotoxicity/cell regeneration as a mode of action for tumor development. An absence of granular casts and linear papillary mineralization discounted the possibility of alpha(2u)-globulin nephropathy as the primary underlying basis in male rats, even though subchronic studies revealed a modest accumulation of hyaline droplets in proximal tubules. Based on the close association of ATH and renal tumors with CPN, it was concluded that chemically induced exacerbation of CPN was the mode of action underlying the development of renal neoplasia, a pathway that is considered to have no relevance for extrapolation to humans.