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E-M:/ Dr. Mike Harbut on Arsenic in Drinking Water

Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>

Michael Harbut, M.D., M.P.H  is a board member of Michigan
Environmental Council and an Physician who is an Occupational
Medicine and Occupational Lung Disease Specialist in Southfield.

This information will be of interest to Oakland County residents
who have had problems with naturally occurring arsenic in 
area drinking water.   If my memory is correct, I believe Dr. Harbut
has also been concerned about this same problem, as noted
in newspaper accounts of the arsenic problem.

Alex Sagady
Enviro-Mich Listmanager

 Subject:  [OEM] Arsenic, EPA
 Date:  Thu, 23 Sep 1999 08:29:23 EDT
 From: M1har@AOL.COM

You all may remember that I posted an inquiry several weeks ago re: EPA
mechanism to determine the new arsenic standard for drinking water.  As
it turns out (and I won't take the low road here and tell you all the
details), the folks responsible at this point at the EPA have decided to not
include a lot of the available data in the decision process of promulgating the
new standard.

For those of you who don't know, arsenic in drinking water has been
stated (in the peer reviewed literature) to be associated with many more
maladies than even very recently believed.  There is an apparent association
between DM, Cardiovascular disease, Lung Disease, Cancers (skin, lung, bladder),
etc.  A very good "review" article is in the May/June issues of Archives of
Environmental Health.

In any case, attached to this posting is a letter to the EPA
administrator which asks her to consider all available data in developing
the new
arsenic drinking water standard, instead of only the data which the staff had
"time to churn" before their internal deadline, to meet the Congressional
Deadline of 1/2000.

If you could find a minute to read it, print in and send it to the epa, I
think it would help promote "good science" instead the so-called "junk
science."  If you don't want to go through that hassle, if you respond
to me that you'd like to "sign on", I'll print out names and forward them to
the EPA myself.  If you do send it on your own, I would appreciate it if you
would let me know.

Forgive the low budget operation, but I don't have anybody financing
this  effort, and my "electronic data resources" are quite limited (to say the
least).  I did get help with the information and letter from the Natural
Resources Defense Council.  The only other disclosure here is that I am
just as concerned about this issue in my life as a parent as I am in my life
as a physician/scientist.


Michael R. Harbut, MD, MPH, FCCP
Diplomat, Am Bd of Prev Med, Occ Med
Chief, Center for Occ/Env Medicine, Southfield, Michigan
Clin. Asst. Professor of Medicine, Wayne State University, Detroit,
Vice-Chair, Occ/Env Hlth Section, American College of Chest Physicians


September   , 1999

The Hon. Carol M. Browner, Administrator
U.S. Environmental Protection Agency
401 M Street, SW	
Washington, DC 20460

Dear Administrator Browner:

We write to you as public health scientists and physicians to express 
our deep concern and disagreement with an apparent interim EPA 
decision on arsenic in drinking water.  This decision could set the agency 
on course to ignore the recent advice of the National Academy of 
Sciences (NAS), and as a result to significantly underestimate arsenic's 
health risks, and to establish an unacceptably weak standard for this 
known human carcinogen.  

Specifically, EPA representatives have made statements (at 
a recent stakeholders meeting on arsenic and elsewhere), and recent 
trade press articles have reported that the agency is unlikely to use 
the NAS's recent risk estimates for total cancers, including lung cancer, 
posed by arsenic exposure from drinking water.  Moreover, public 
statements suggest that EPA may review, but likely will not seek to 
quantify, the extent of many other adverse health effects of arsenic 
other than fatal bladder cancers.  These would include cutaneous effects, 
impacts on the cardiovascular system or gastrointestinal tract, potential 
reproductive effects, skin and non-fatal cancers, diabetes, and other effects. 
(National Research Council, Arsenic in Drinking Water (1999)).  

This is of particular concern since, as the Academy noted, "a wider 
margin of safety might be needed when conducing risk assessments of 
arsenic because of variations in metabolism and sensitivity among 
individuals or groups."  For example, evidence "suggests that children 
have a lower arsenic [detoxification] efficiency than adults." (Ibid, p. 5
This fact, and other data suggesting that children likely are at elevated 
risk from arsenic (see for example, P. Mushak, "Arsenic and Human Health: 
Some Persisting Scientific Issues," in Arsenic Exposure and Health, ch. 31, 
p. 307 (W.R. Chappell, eds, 1994)), merit particular EPA attention under 
the 1997 Executive Order on "Protection of Children From Environmental 
Health Risks and Safety Risk," and the Safe Drinking Water Act's provisions 
regarding protection of vulnerable populations including children.

Scientifically, EPA's interim approach failing to fully consider and quantify 
the full array of arsenic's risks is hard to justify.  The failure to
quantify these 
health effects also would artificially lower estimates of the risks from
in drinking water.  Under EPA's cost-benefit standard setting approach, this 
would reduce the presumed benefit of taking action to reduced levels of 
arsenic in the tap water of millions of Americans' tap water. Ultimately,
such an 
inaccurately-derived calculation of costs and benefits could result in a legal 
standard for arsenic in drinking water, or Maximum Contaminant Level (MCL), too 
weak to protect public health. This is a serious concern, since the current
standard has remained unchanged since 1942, despite decades of efforts 
from health experts, dating back at least to 1962 Public Health Service
to substantially strengthen the standard.

Recently, the NAS' 1999 arsenic panel reached the "consensus that the current 
EPA MCL for arsenic in drinking water of 50 mg/L does not achieve EPA's goal 
for public-health protection and, therefore, requires downward revision as
as possible." (Arsenic in Drinking Water, pp. 8-9 (1999)).  Moreover, the 
Academy stated that "for male bladder cancer…[Academy estimates] yielded a 
risk at the MCL of 1 to 1.5 per 1,000.  Because some studies have shown 
that excess lung cancer deaths attributed to arsenic are 2-5 fold greater 
than excess bladder cancer deaths, a similar approach for all cancers 
could easily result in a combined [fatal] cancer risk on the order of 1 in 
100." (Ibid p. 8).  This would mean that even an MCL of 5 mg/L may present 
a combined fatal cancer risk on the order of 1 in 1,000—at least an order of 
magnitude higher than the cancer risk that EPA traditionally accepts in
drinking water.

We are deeply troubled by the possibility that EPA may reject the National
of Science's considered view on the need to quantify lung cancer and to 
seriously consider the many other serious health risks of arsenic,
particularly to 
children and other vulnerable people.  We urge the agency instead to follow the 
NAS' lead, and to quantify and use in cost-benefit calculations for arsenic in 
drinking water, the full array of fatal and non-fatal cancers (bladder,
lung, and skin), 
other cutaneous effects, impacts on the cardiovascular system and
tract, potential reproductive effects, diabetes, and other effects.


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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