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Re: E-M:/ review of deq pollution standards



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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At 10:06 AM 2/1/1999 -0500, Dave Dempsey wrote:
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>Enviro-Mich message from Dave Dempsey <davemec@voyager.net>
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>
>Today marks the first meeting of a special panel of the Michigan
>Environmental Science Board to review the adequacy of state pollution
>standards to protect children.  Governor Engler requested MESB to establish
>such a panel after pressure from MEC and other children's health advocates.
>
>The Legislature ordered the review at MEC's request.  The 1999 DEQ
>appropriations bill contains a provision which contains $100,000 "for
>research on the adequacy of department standards to protect children's
>health" and calls for a report to be submitted to the Legislature by
>September 30, 1999.
>
>This arises out of MEC's concern that Michigan's historic reluctance to
>embrace fish consumption advisories protective of children is indicative of
>a broader lack of sensitivity to the effect of air and water pollution on
>this vulnerable group of Michiganians.  EPA, the State of California and
>several other jurisdictions have aggressively pursued the issue of
>children's environmental health protection.  

Actually, this is probably too narrow a focus on this issue.

For example, Michigan's methods for calculating acceptable ambient
concentrations, known as Initial Threshold Screening Levels, under Michigan's 
airborne toxicant rules for new and modified sources,
calculates acceptable dose levels with the assumption
of a 70 kilogram adult for non-carcinogens on certain toxicants.

While this is protective for those of us who are desk-bound environmental 
adult bureaucrats at about 100+ kilograms, it won't necessarily allow a large
enough safety margin for elucidating exposures for children.

Michigan's complete failure to enact existing source airborne toxicant rules
other
than the minimums required by the Federal Clean Air Act is largely as a result
of resistance from the Michigan Manufacturers Association, Dow Chemical, 
Upjohn (whatever their name is these days), the Chamber of Commerce and
other overly interested parties.  

There is no assurances of childhood protection
(or anybody else for that matter) from unreasonable risks and excessive
exposures
as long as there are no existing source airborne toxicant rules, no 
environmental review process for major state actions, no review of
non-inhalation
parthway risks, etc. and other defficiencies in Michigan's patterns of
health and 
environmental risk assessment and risk management activities for airborne
toxicant
emissions.


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Alex J. Sagady & Associates        Email:  ajs@sagady.com
Environmental Consulting and Database Systems
PO Box 39  East Lansing, MI  48826-0039  
(517) 332-6971 (voice); (517) 332-8987 (fax)

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