Subject: Top EPA dioxin expert resigns, Midlanders never fully informed of risks
Date: December 12, 1985
The following is a letter written by Dr. J. Milton Clark, EPA Region V Health Effects Specialist:
Dr. Clark's scientific document detailing dioxin risks in Midland was captured by the policymakers at EPA headquarters in Washington.
The final document released to the public was influenced by Dow, Midland City Officials and some of our elected officials that Dow recruited.
Midlanders were never fully informed of the risks and were instead told that the risks from dioxin were " acceptable."
It appears that we are repeating this pattern today. Political influence seems to be winning again.
We're still at risk, the area of contamination (that should have been addressed years ago) is now massive and Dow hasn't even begun to clean-up their offsite messes.
Dow continues to create delays by distracting the public with exposure studies, lobbying the agencies to change the clean-up numbers and reassuring the public that there is no risk. Midland City officials and some of Dow's favorite politicians are blindly following, despite their lack of knowledge.
It appears that we are now waiting for behind-closed-door "negotiations" to end.
I find it hard to believe that these negotiations will be science-based, but rather a result of heavy lobbying and pressure placed on the agencies to AGAIN assure Midland and downstream residents that the risk is "acceptable."
That's been the story here for years and the outcome of this type of negotiating should now be obvious.
I am still trying to remain optimistic that the agencies will not cave into these pressures, AGAIN.
Subject: Withdrawal from all Regional Activities Involving Dioxin
From: J. Milton Clark
To: David Stringham
This memorandum serves to inform you that I will be withdrawing from all regional activities involving dioxin. This includes my planned participation in the newly designated workgroup on dioxin emissions from incinerators and providing health based risk assessments for dioxin in the Region.
Working with dioxin activities over the past few years has been a rewarding and worthwhile experience, beginning in 1981 when, upon request, I compiled all our existing regional data available on dioxin and dibenzofurans. As you know, this resulted in the report, "Polychlorinated Dibenzo-p-dioxins (PCDDs) and Polychlorinated Dibenzofurans (PCDFs) : A Summary of Studies Conducted in the Great Lakes Area." This report helped us all to begin to identify what problems existed in our Region, including DOW CHEMICAL, and to gain an understanding of the risks frrom consumption of dioxin tainted fish from the Great Lakes.
Perhaps the high point, although a stressful time for us all, was the 1983 congressional hearings concerning the 1981 report when Val Adamkus, Karl Bremer, myself, and others represented the Region to defend the validity of the conclusions of that report and to establish the need for additional studies to assess dioxin contamination in MIDLAND and elsewhere in the environment. The hours I devoted in preparing the Regional response to Congress, including reducing my commitment to the university at that time, all seemed very worthwhile and critically important to the Agency and its course of direction.
Shortly after the Congressional hearings, in which DOW CHEMICAL appeared, a wastewater discharge agreement concerning dioxin was finalized. No doubt having public focus on the issue of dioxin emissions from the DOW facility, aided Region V gain an agreement with DOW CHEMICAL.
Also in the same year, EPA announced a national dioxin strategy to assess dioxin contamination in Michigan and across the country.
The 1981 report also clearly identified that soil concentrations on the DOW CHEMICAL property exceeded the 1 ppb level established by CDC as being of concern and led to our Regional efforts to identify sources and extent of contamination in MIDLAND.
This regional effort, FOR THE FIRST TIME HELPED REFUTE THE LONG STANDING ARGUMENT OF DOW CHEMICAL THAT DIOXINS WERE FOUND EVERYWHERE IN OUR ENVIRONMENT AND WAS DUE TO COMBUSTION. DOW CHEMICAL has agreed to cover over sites of significant dioxin contamination.
Looking back at all which has happened regarding dioxin one wonders how much of this activity would have occurred if that 1981 report had not been written and such important information as dioxin contamination in MIDLAND and the risks of consumption of dioxin tainted fish had not been included. Hopefully this report will be viewed as having made important regional and perhaps national contributions, as well as my time devoted to its preparation and defense before Congress.
More recently, my 1985 development of a RISK EVALUATION of all of our data from MIDLAND should hopefully serve you and the Dioxin Task Force, and the State of Michigan, in making fully informed decisions regarding the need for remedial actions in MIDLAND.
As you are fully aware, this detailed risk assessment was prepared because of the GREAT INADEQUACY OF THOSE WRITTEN BY CDC AND HQ'S WORKGROUP. These poorly prepared, undocumented "assessments" could, in no manner be used to intelligently reach conclusions.
In fact neither of these reports stated what the risks to individuals exposed to dioxin at the levels observed in MIDLAND. Before the first draft of risk assessment was finalized, I informed you of its pending release. While you characterized the report as "unauthorized", as a member of the Dioxin Task Force, and probably the only one with sufficient expertise in dioxin risk assessment and related health issues, it certainly was my role and responsibility to the Agency, given the poor assessments previously produced by CDC and HQ, to generate a solid, scientific document. While this entire issue has been a sore point for both of us, ultimately the production of this document will be viewed as having merit and making a contribution to the Region and Agency in general.
Some final matters should also be addressed. I hope you and other members of the Dioxin Task force appreciated my efforts over the past years, including the handling of public and Congressional control correspondence and providing technical information regarding dioxin whenever possible. It has always been my intent and desire to serve others in this capacity and in the future I shall attempt to do so in other areas.
Regarding the MIDLAND RISK ASSESSMENT, I would request that the Dioxin Task Force and others, objectively look at the document and determine if you all believe that no risk reduction or health studies are needed in MIDLAND.
As a scientist and professor of public health, I find that the advice of CDC to be very incomplete and opinionated and I am deeply concerned with the quality of advice which CDC is providing the agency on a number of topics, including our MIDLAND study.
Finally, the Dioxin Task Force, as well as senior management, should discuss if they believe that a lower dioxin value for residential soils based upon ORD's risk assessment, and as used in my report, is warranted.
It has been a great pleasure working with you and others of the Dioxin Task force. I shall miss the stimulating discussions and activities of the task force and i will look back at those times as having provided some of my most rewarding experiences with the Agency. The very best to you all.
For additional articles like this one, go to the Tittabawasse River Watch web site www.trwnews.net. for complete coverage of the Tittabawassee River Dow Chemical dioxin contamination saga.. The source organization's web site link is listed above. The Newspaper / Media page of our site contains an extensive archive of media articles dating back to January 2002. The Newspaper / Media page may be accessed by scrolling down to the bottom of the CONTENTS section and clicking on the Newspaper/Media link.