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E-M:/ Michigan DEQ and Health Dept. Do the Right Thing on HHS-ATSDR Mercury Issue



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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Michigan DEQ and Michigan Dept of Community Health do the right
thing on HHS-ATSDR Mercury oral exposure standard Issue....

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April 1, 1999

Dr. Donna Shalala, Secretary
U.S. Department of Health and Human Services
200 Independence Ave. S.W.
Washington DC  20201

Dear Secretary Shalala:

We are writing to you to express our concern about the proposed 
Chronic Minimal Risk Level (MRL) for oral exposure to methylmercury
which the Agency for Toxic Substances and Desease Registry is 
apparently going to adopt very shortly.

Out agencies previously sent a letter to the Administrator of the 
ATSDR regarding the draft "Toxicology Profile for Mercury" (see
attached letter).  The primary issue that concerns Michigan is the development 
of a Chronic Oral MRL.  The proposed draft Chronic Oral MRL for 
methylmercury, at 0.5 micrograms per kilograms per day (ug/kg/day), is four 
times higher than the previous Acute/Intermediate MRL, and is four times
higher than
the reference dose for methylmercury developed by the U.S. Environmental 
Protection Agency and included in their final Mercury Study report to Congress
submitted December 1997.  We continue to be concerned that these differing 
numbers will cause confusion at the state level when developing policies and
procedures
related to determining the safe exposure level of methylmercury for the citizens
of Michigan.  It is essential that federal government agencies involved in 
establishing mercury health benchmark values speak with one voice on this 
important issue.

We are also still concerned that theATSDR did not use all of the published 
literature in developing this MRL.  Important data on the effects of prenatal
exposure to methylmercury and associated effects on child development 
have been published in the Journal of Neurotoxicology and Teratology 
(Grandjean et al., 1997).  This data should also be reviewed and evaluated when 
considering a methylmercury health benchmark.  We believe ATSDR should delay
the release of the Toxicological Profile for Mercury until additional
results from
ongoing studies and the National Academy of Science review can be
incorporated in
the mercury MRL assessment.

Mercury continues to be a high priority pollutants for Michigan.  We hope the 
ATSDR will use the best available data in developing a MRL that is protective
of all citizens, including sensitive populations.

Sincerely,

Dennis M Drake, Chief
Air Quality Division
Department of Environmental Quality
517 373 7069

David Wade, Acting Administrator
Environmental Epidemiology Division
Department of Community Health
517 335 8350

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Alex J. Sagady & Associates        Email:  ajs@sagady.com

Environmental Enforcement, Technical Review, Public Policy and
Communications on Air, Water and Waste Issues
and Community Environmental Protection

PO Box 39  East Lansing, MI  48826-0039  
(517) 332-6971 (voice); (517) 332-8987 (fax)
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