June 14, 2004 (FAXED & EMAILED)


Representative James Koetje

Michigan State Capitol

PO Box 30014
Lansing, Michigan 48909-7514                                       


RE: Hearing to discuss Direct Residential Contact Criteria for dioxin in soils

Dear Representative Koetje and all members of the Committee on Governmental Affairs,

I am writing on behalf of the Environmental Health Fund, a national environmental and public health NGO focused on issues of chemical impact to public health. We are writing to urge you and all members of the Committee on Governmental Affairs to vote against any proposal to increase direct residential contact criteria for dioxin in soils from the state standard of 90 parts per trillion to the suggested 1,000 parts per trillion. Any increase would be inappropriate.

 Dioxin is a proven human carcinogen.  It is this fact and a sincere interest in protecting public health that lead the Boston City Council on August 27, 2003 to vote 13 – 0 in favor of a Dioxin Reduction Resolution.  Councilman Felix Arroyo introduced the unanimously held resolution.

 There were many convincing speakers at hearings to discuss this issue.  Physicians, researchers, labor leaders, healthcare representatives, academics, and health impacted group representatives all spoke in favor of the resolution to reduce exposure to dioxin. 

Here is what Paul Atwood, PhD, from The William Joiner Center for the Study of War and Social Consequences told the council:

 "As an early advocate for veterans on this issue [of dioxin exposure] I found that one of the most tragic aspects of the entire struggle was the record of deceit and cover-up practiced by the government and the chemical companies responsible for the manufacture of dioxin, including the giants Dow and Monsanto.

"The chemical companies own records indicated that their own scientists knew that Agent Orange was laced with high levels of dioxin and that they also knew of its carcinogenic and teratogenic effects. Yet this information was suppressed."

Mr. Chairman and members of the Committee, I urge you to heed Dr. Atwood’s remarks when you listen to the state of Dow science on the "safety" of dioxin exposure at 1,000 parts per trillion levels. Their record of information suppression must be considered.  I further urge you to vote against any proposal to increase the state standard from 90 parts per trillion.

On July 2, 2003, as the Boston City Council was considering the dioxin reduction resolution, The New York Times reported that the Institute for Medicine, a health policy advisory body, "recommended the government do more to educate women and girls about how to limit their consumption of dioxin, which can be passed through the placenta to a fetus or through breast milk to an infant."

As the Institute of Medicine is raising alarms about exposure to dioxin and calling on government to act in protection of women and girls, your committee is contemplating relaxing these alarms.  To do the latter would appear to be wholly out of step with the state of the science on dioxin; science that is well understood and convincing in its utter indictment of dioxin exposure. 

We urge you not to set yourselves in contrast to governments in cities like Boston, Buffalo, Seattle, Oakland, San Francisco and in states like Washington and Oregon, which have taken action to better arm agencies and the public to understand and address the threat of dioxin exposure.

The only difference between the fine people in government in these locations and the fine people in government in Michigan is that none of the aforementioned have Dow Chemical headquartered in their area.  I entirely trust that the profits of this corporation will not be set above the protection of Michigan residents by their own publicly elected members of government.  

We urge each member of the council to vote against a proposed relaxation to the Direct Residential Contact Criteria for dioxin in soils.

Thank you for considering my letter.  Please share it with all members of the Committee on Governmental Affairs.




Judith Robinson

Special Projects Director

cc: Boston City Councilman Felix Arroyo


Environmental Health Fund • 41 Oakview Terrace Jamaica Plain Massachusetts  02130

617-524-6018 (t); 617-524-7021 (f)