Subject: Risk evaluation of data collected ruing EPA's field study of Midland Michigan
May 4, 2003
Please share this information with others who are not aware of the history
of the ongoing risks from exposure to dioxin and other toxic chemicals in
The credibility of current and previous CDC, ATSDR and MDCH decsionmaking
must be addressed.
It is clear that these decisions have not been in the best interest of
protecting residents exposed to dioxin and other chemicals in Midland.
Interim protection and clean up of these poisons have been put on the back
burner for years due to Dow's influence.
I would suggest that all state and federal agency officials involved with
the Midland site take the time to read the 1984 multi-media risk assessment
I believe that Dr. Clark recommended a 40 ppt clean up standard, at that
Since then studies on non-cancer effects have piled up, suggesting time and
time again, that there is no level of dioxin that doesn't cause some adverse
health or reproductive effect.
Clearly, the recommendations and advice coming from ATSDR to use a 1 pppb
clean up standard is outdated, scientifically indefensible and not
applicable for a site as highly (and completely) contaminated as Midland.
Re: 1980's EPA Dioxin Study in Midland
RISK EVALUATION OF DATA COLLECTED DURING U.S. EPA'S FIELD STUDY OF THE
MIDLAND, MICHIGAN AREA.
( J. Milton Clark, Health Effects Specialist,EPA Region V).
Selected Excerpt: AIR??
11. AMBIENT AIR DATA
Data provided by Dow Chemical on 2,3,7,8-TCDD concentrations in ambient air
are presented below in Table E (2). A total of 10 measurements were taken
within the Dow Plant, six at the Dow Plant fenceline and two in the city of
ALL SAMPLES WERE FOUND TO BE POSITIVE FOR 2,3,7,8-TCDD.
THE DATA GENERATED INDICATE RATHER LARGE FLUCUATIONS IN AIR CONCENTRATIONS
Subject: Response to April 26, 1985 Comments Provided on the February 28,
1985 Region V Risk Assessment of Midland,Michigan Data
To: Georgie A. Jones
Superfund Implementation Group
From: J. Milton Clark, Ph.D
Health Effects Specialist
A evaluation of this data, shown below, clearly indicates that 2,3,7,7-TCDD
is found at concentrations at one to two orders of magnitude greater in
Midland soils than in those sampled in industrialized areas.
The ratio of mean soil concentrations around the Dow facility is
approximately 150 times greater than the mean calculated from the perimeter
of the Armco plant. The concentration of 2,3,7,8-TCDD observed in soils FROM
PUBLIC USE AREA OF MIDLAND AVERAGES 30 TIMES THAT FOUND IN PUBLIC USE AREAS
FROM MIDDLETOWN, OHIO.
RESIDENTIAL SOIL LEVELS IN MIDLAND AVERAGE 12 FOLD HIGHER THAN THOSE
OBSERVED IN MIDDLETOWN, OHIO.
If Dow Chemical's data of average soil concentrations of 2,3,7,8-TCDD from
20 industrialized cities is compared to that found in Midland and along the
perimeter of the plant, the ratio is 37 FOLD.
CLEARLY, MIDLAND HAS SOIL CONCENTRATIONS OF 2,3,7,8-TCDD WHICH ARE NOT
COMPARABLE TO THOSE FOUND IN OTHER INDUSTRIALIZED AREAS OF THE UNITED
MIDLAND IS UNIQUE COMPARED TO OTHER AREAS WHERE DIOXIN HAS BEEN FOUND. For
instance, a portion of Midland's population has had occupational exposure to
PCDDs and PCDFs as reported by Dow Chemical. The extent of this exposure is
Chlorophenoxy and related compounds have been manufactured in Midland for
over 40 years and disposal practices, such as incineration were poorly
controlled to prevent releases of PCDDs and PCDFs.
THEREFORE AMBIENT AIR LEVELS OF PCDDs and PCDFs WERE LIKELY TO BE
SUBSTANTIALLY HIGHER THAN THOSE OBSERVED CURRENTLY.
FOR LONG TERM RESIDENTS RESIDING NEAR THE DOW PLAN, ACCUMULATED RISKS FROM
EXPOSURE TO PCDDs and PCDFs VIA AMBIENT AIR ALONE MAY ALREADY HAVE REACHED
Further complicating this risk picture would be consumption of fish from the
Tittabawassee River. Exposure to garden vegetables (historically and
currently) also needs to be determined.
THEREFORE, AN OPEN QUESTION REMAINS IF CONTINUED EXPOSURE TO PCDDs and PCDFs
VIA SOIL OR AIR FOR CERTAIN SUBPOPULATIONS OF MIDLAND RESIDENTS IS
SOME CONSIDERATION MUST ALSO BE GIVEN TO THE ALREADY SUGGESRIVE HEALTH DATA
FROM MIDLAND COUNTY WHICH INDICATES AN ABNORMALLY HIGH RATE OF SOFT TISSUE
SARCOMAS AMONG WOMEN AND AN EARLY 1970'S RISE IN BIRTH DEFECTS OF COMPARABLE
ETIOLOGY WITH 2,3,7,8-TCDD.
Source: Diane Hebert