To put those DEQ comments posted by Dave Dempsey in perspective and
to best understand what appeared to be a great deal of disagreement
between DEQ and Dow, I encourage you to go to the Dow Chemical link below and
read the November, Dow Community Update.
DEQ's positions on these issues are paramount to public health and natural
resource protection. They are important in public engagement and education
about the effects of dioxin on our lives, property values, and economic vitality
of the Saginaw Bay Watershed. It's likely that Dow will continue
operate their misinformation campaign. What remains uncertain is whether
the Granholm administration will permit the DEQ to respond to Dow's
misinformation campaign.
Here's the link to Dow's November Newsletter:
Michelle Hurd Riddick
Lone Tree Council
In a message dated 2/25/2005 10:50:32 P.M. Eastern Standard Time,
davedem@hotmail.com writes:
Enviro-Mich message from "Dave Dempsey"
<davedem@hotmail.com>
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Pardon
the long post, but I agree with DEQ communications director Patricia
Spitzley that "The more information and education people can receive about
the effects of dioxin the better." In that spirit, here are the full DEQ
staff draft comments on Dow's November community update that were, for
some
reason, never released.
Comments on Dow’s November 2004
Community Update
1. Page 1, Column 1, Paragraph 2:
This is an overly generalized and
ambiguous statement. The
Environmental Protection Agency, International
Agency for Research on
Cancer (IARC), U.S. Department of Health and Human
Services, and other
government organizations recognize 2,3,7,8-TCDD as a
known human
carcinogen and dioxin mixtures (toxic equivalence or TEQ) as
suspected or
probable human carcinogen.
2. Page 1, Columns 2 and
3: It is difficult to review this section because
Dow would not
provide the actual study results or even a copy of the
Powerpoint
presentation given to staff of the Departments of Community
Health (DCH)
and Environmental Quality on November 3, 2004. DCH staff
requested
this information on November 4, 2004. Dr. Michael Carson of Dow
declined to provide the requested information.
3. Page
1, Column 2, Paragraph 3: The heading of this section states “No
Indication of Health Effects” and the text indicates that Dow finds
“little
indication of any health effect related to dioxin exposure in our
chlorophenol workers.”
4. Page 1, Columns 2 and 3,
Paragraph 6: In 2004, this is the range Dow
reports. Dioxin is
eliminated from the body with a half life of
approximately seven
years. If the Dow reported levels are corrected for
elimination via
half life, this range would be much higher. It is not
accurate to
compare the 2004 Dow data to the levels reported by the Centers
for
Disease Control which are the estimated highest serum levels at the time
of last exposure.
5. Page 1, Columns 3, Paragraph
2: The section, “People More Resistant,” is
misleading. The
statement cited is not proven for all adverse effects that
have been
associated with dioxin exposure. For example, for effects that
have
been clearly associated with dioxin exposure, such as chloracne and the
induction of liver enzymes, humans and animals respond at similar body
burdens. For some effects, humans are more sensitive than certain
other
mammalian species (e.g., chloracne in mice, cancer in hamsters,
decreased
testosterone in rats).
6. Page 2, Column1,
Paragraph 4: The more comprehensive studies by National
Institute
for Occupational Safety and Health (NIOSH) and IARC do show
increased risk
of disease (cancer, ischemic heart disease). These results
were
reaffirmed in 2004. Dow should cite the study to which they
referred.
7. Page 2, Column 2, Paragraph 4: The
bioavailability study design has not
been approved by the DEQ. An
independent peer review by Toxicology
Excellence in Risk Assessment (TERA)
indicates that there are major problems
with the study design. In
addition, it has not been demonstrated at this
location that dioxins are
“firmly bound” to soil and are not readily
absorbed into the blood.
In fact, based on Dow’s wild game study and
Michigan State University’s
(MSU) ecological risk studies, dioxins in the
Tittabawassee River
floodplain appear to be very bioavailable.
The German study referred to
in this discussion may not be relevant as
bioavailability varies based, in
part, on soil type and contamination.
8. Page 3, Columns 2
and 3: Dow’s graphs and comparisons are flat out
misrepresentations
of the actual facts, data, and model for the DEQ’s
screening level
terrestrial ecological risk assessment (ERA) evaluation.
The DEQ
made no estimates of the level of contamination expected to be
present in
squirrels and turkeys from the Tittabawassee River floodplain.
It
would have been, and is, inappropriate to use the DEQ’s screening level
terrestrial ERA to attempt to make such calculations.
The DEQ was,
in fact, surprised by the high levels of dioxins found in the
portions of
squirrels, turkeys, and deer consumed by humans. Higher levels
of
contamination are expected to be present in portions of animals that are
consumed by prey species. The recently released MSU ecological data
support
the DEQ’s conclusion that ecological risk from dioxins is present
in the
Tittabawassee River floodplain. Levels of dioxin in small
ground dwelling
mammals is on the order of 100 times higher than the
squirrel data reported
by Dow.
9. Page 4, Column 3,
Paragraph 1: The “guidelines” referred to in this
paragraph are
actually concentration ranges. Exposure to these
concentration
ranges may result in adverse health effects. Some studies in
humans
have shown adverse health effects associated with background levels
of
dioxin.
10. Page 5, Columns 1 and 2: The Interim
Response Activities (IRAs)
referred to in this section have not been
approved by the DEQ. This section
does not discuss critical
components of the IRAs, which include advisory
signage to reduce exposure
to contaminated soil and fish.
Please note that “permit approval”
likely refers to floodplain permits, not
Part 111 approval of the IRAs for
corrective action purposes as is implied
by the wording.
11.
Page 5, Column 3, Paragraph 1: Based on Dow’s November 3, 2004
presentation to DCH and DEQ staff, chloracne did not predict serum dioxin
levels (i.e., some workers with high dioxin levels did not exhibit
chloracne).
Dow’s exposure estimates did not predict actual
measured dioxin levels as
stated in this paragraph. Instead, they
predicted relative levels of
exposure.
12. Page 5,
Column 7: Although Dow briefed DCH and DEQ staff on the worker
study, Dow declined to provide the actual study results when requested to
do
so on November 4, 2004.
13. Page 6, Column 2,
Paragraph 2: A publication of the study cited by Dow
supports the
TEQ approach, which is an order of magnitude estimate of
overall toxic
potency (not just cancer). Also, it should be clarified that
toxic
equivalency factors (TEFs) are developed based on specific toxicity
studies of the individual compounds. The TEF for 2,3,4,7,8-PeCDF
(not
2,4,7,8-PCDF) estimated from this study were 0.16 to 0.34 for four
tumor
types, which are within half an order of magnitude of the current
TEF of
0.5. The study cited here also verified that the cancer
incidence from a
mixture of three dioxin-like compounds was adequately
predicted by the TEF
approach and did not over-predict toxicity as implied
by Dow.
14. Page 7, Column 1, Paragraphs 3 and 4:
The University of Michigan Dioxin
Exposure Study (UMDES) as designed will
not be able to conclusively
determine the exposure of the specific
population of greatest concern,
residents who live on properties that
frequently flood. Also, as noted
above, even if these residents have
dioxin levels within the background
range, it does not mean that there
will be no increased health risk.
The DEQ will not be able to use the
UMDES for corrective action purposes as
described here. In addition,
it is not appropriate to wait until the study
is completed in 2007 to
begin to take actions to reduce exposure.
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