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E-M:/ DEQ responds to the Chamber on Dow and dioxin

Perusing the DEQ website I caught this outstanding letter from Steve
Chester to the Detroit News responding to a letter to the editor written
by Doug Roberts of the Chamber.  This is the clearest, most direct
response I’ve seen to the hysteria created in the Midland area by
Legislators and others who have been working hard to prevent the DEQ
from protecting the public health.  Bottomline – even IF the Legislators
enact the unsupportable effort to roll up contamination limits for
dioxin, there are properties along the Tittabawassee River that are
contaminated at levels universally considered unsafe, and Dow Chemical
is responsible for the contamination.  While there is cause for concern
that the political quagmire intentionally created by Legislators is
slowing down the process for addressing the contamination, it is very
encouraging to see Director Chester put forward the simple straight
forward rationale for why this process must move forward. As far as I
can tell this letter has yet to be printed -- I hope the News prints it
so it gets the coverage it deserves.  For the original go to:
Anne Woiwode
                                                              June 28,
Letter to the Editor
The Detroit News
615 West Lafayette
Detroit, MI  48226
Dear Editor:
In his June 24, 2004 guest editorial, Mr. Doug Roberts, Jr. of the
Michigan Chamber of Commerce, charges the Department of Environmental
Quality (DEQ) with launching “a vague, ill-conceived plan” to address
dioxin contamination based upon “a lack of facts and disregard for sound
science.”   How unfortunate that a representative of one of Michigan’s
most prestigious members of the business community must rely on sound
bites, and convey inaccurate and misleading information, in the public
debate over one of the most significant policy issues facing Michigan
The facts are these: data gathered by both the U.S. Environmental
Protection Agency (EPA) and the DEQ demonstrate dioxin contamination in
Midland soils, sediments of the Tittabawassee River, and in soil on
properties along the River.  No one knows precisely how many properties
are contaminated or at what levels.  What we do know is that some
properties are contaminated at levels which pose a public health risk as
defined by the Michigan Legislature.   The contamination of the River
sediments has been shown to be harmful to fish and animals.  We also
know that The Dow Chemical Company (Dow) caused the dioxin
contamination.  As such, under both federal and Michigan law, Dow is
responsible to address that contamination.
The level of dioxin contamination in the Midland area that some would
declare “safe” poses ten times more risk to public health than the
current standard derived under Michigan law.  Of the states that have
derived safe levels of dioxin in soil, seven are lower than Michigan and
two are only slightly higher.  None would find acceptable the levels of
dioxin found in some Midland area and Tittabawassee River floodplain
soils.  Recent work conducted by the International Agency for Research
on Cancer, the World Health Organization, the United Nations Food and
Agriculture Organization, the European Commission Scientific Committee
on Food, and in EPA’s draft dioxin reassessment supports even lower
And just what is this “vague, ill-conceived plan” with which the DEQ is
charged?  Consistent with federal and state law, Dow must undertake four
basic actions: First, take immediate steps to reduce the highest risks
where, for example, children—the most susceptible segment of the
population—have the greatest chance of being exposed to the highest
levels of dioxin contamination.  Second, help people living in the
Midland and Tittabawassee River areas understand what steps they can
take to reduce the risk of dioxin exposure.  Third, map where dioxin
contamination exists in the area and at what levels.  Finally, based on
the studies and evaluations that will certainly take a year or more,
develop and conduct a long-term plan to address dioxin contamination
above levels considered safe.   The DEQ and Dow are currently engaged in
productive discussions on each of these objectives.  
It is said that even this fundamental and reasonable approach is
unwarranted because there is “no evidence” of anyone in the Midland area
getting sick from dioxin.  However, this is not because an illness has
not occurred but because of the scientific rigors necessary to pinpoint
the precise cause behind a given individual’s illness.  The U.S.
Department of Health and Human Services, the National Institute for
Occupational Safety and Health, and the World Health Organization’s
International Agency for Research on Cancer, as well as the EPA, have
concluded, based on literally hundreds of animal and human studies, that
dioxin is a potent human carcinogen.  The DEQ is doing no more than
responding to what the dictates of law and weight of scientific evidence
Environmental contamination can surely pose significant public health
and environmental concerns.  Michigan needs a system of government that
supports a healthy environment and economic enterprise.   Balancing
these concerns in the context of dioxin contamination in the Midland
area will undoubtedly have important implications for that area and the
entire state of Michigan.  To suggest that the DEQ is acting arbitrarily
and relying on invalid science in this matter does a disservice to both.
Steven E. Chester
Link to Detroit News Article: 
Anne Woiwode, Director
Sierra Club Mackinac Chapter
109 East Grand River Avenue,  Lansing, MI  48906
ph: 517-484-2372 fx: 517-484-3108 e: anne.woiwode@sierraclub.org
website:  http://michigan.sierraclub.org