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MCLS, VOCs, Child Cancer, and Sustainablilty


If cancer is the number one killer of children in this country,
and child cancer is on the rise according to the National Cancer Institute
and volatile organic compounds (VOCs) in drinking water can cause cancer in
children according to the EPA,
then establishing a MCL for VOCs in drinking water to protect children from
cancer risk without using a Risk Estimate modeled on a child's weight and
consumption patterns is without regard to the safety of this subpopulation.

Particularly since child cancer is acute and on the rise.

Shouldn't protecting children with MCLs for VOCs specifically designed with
the risks associated with that subpopulation be the starting point for
protecting the health of the nation?

Donald Sutherland
Member of the Society of Environmental Journalists

-----Original Message-----
From: Robert A. Michaels <76517.747@compuserve.com>
Date: Wednesday, September 08, 1999 10:16 AM
Subject: Re: MCLS, VOCs, and USDW


        As a health risk assessor, I have worked on preparing drinking
water criteria documents at a consulting firm under contract to support US
EPA promulgation of drinking water standards under the Safe Drinking Water
Act.  I can say that the idea that MCLs are promulgated without regard to
their safety to sensitive subpopulations, most notably infants and pregnant
women, is unbalanced and incorrect.  A more correct concept is that MCLs
may compromise stringency to establish standards attainable in practice in
the near term, whereas MCLGs (Maximum Contaminant Level Goals) are more
stringent, though they may be attainable only with long-range planning.
Indeed, zero MCLGs for carcinogens may be unattainable ever, but

        Concern expressed about MCL protectiveness to infants seems to have
arisen from EPA use of the (once) standard assumption of a 70-kg adult
drinking 2 L of water each day.  Consider, however, that infants often are
breast-fed.  When not breast-fed, they typically consume commercially
prepared formula, which may come ready-to-consume, or may require dilution
with local water (or, more to the point, the local water is diluted with
formula before consumption).  Finally, although the MCL may be expressed as
a substance concentration in drinking water, that concentration typically
was derived based upon internal doses attained in studies involving animals
and/or humans; including studies of reproductive, fetotoxic, and
teratogenic effects; as may have been available.  One of these effects may
or may not represent the 'critical' effect which formed the reported basis
for MCL derivation for a specific substance, but if the reported basis was
different, that does not mean that reproductive, fetotoxic, and teratogenic
effects were unconsidered in deriving the MCL.

        In my view, the bottom line is that drinking water standards may be
imperfect.  Some individual MCLs might be found to be inadequate, and
perhaps should be revisited, especially in light of emerging research.
However, in my experience MCLs do not wantonly disregard the need to
protect infants, pregnant women, and other sensitive subpopulations.

Robert A. Michaels, PhD, CEP
RAM TRAC Corporation
3100 Rosendale Road
Schenectady, NY  12309-1510
(518) 785-0976 (voice)
(518) 785-0976 (telecopier)