To: Cheryl Howe
From: Diane Hebert
Date: 10/10/03
Subject: Comments on Dow SOW for Midland

Dow's Scope of Work Proposals are a continuation of 'Business as Usual'.


Since at least 1978 Dow has managed to delay regulatory action to protect
public health and the environment from their deadly byproduct by peddling
their 'Trace Chemistries of Fire' theory to confuse the public and delay
both state and federal intervention.
In fact as early as the 1930's Dow scientists warned managment that their
biocides were contaminated with a highly toxic byproduct and suggested that
Dow stop production until further study.
Dow management ignored these warnings and continued production.

In 1983 two small environmental groups filed a petion with the EPA under
TSCA requesting a full field investigation of Midland and the surrounding
areas to determine the full extent of contamination from Dow's dioxin and a
multitude of other toxic chemicals released to the air, land, water, and
chemical injection system.

In 1984 the EPA released part of their Midland study finally trashing Dow's
"Trace Chemistry of Fire' theory. that suggested God gave us dioxin.
Levels of dioxin found in Midland soils were found to be far higher that
other comparable cities in the U.S. The EPA concluded that Dow's hazardous
waste incinerator was the culprit for the majority of dioxin found in
Midland County. Other possible dioxin sources were not fully evaluated at
that time.

In 1986 the EPA released data showing that Tittabawassee River carp found
downstream from Dow were contaminated with dioxin at 695 ppt. This number
was the highest level found in the EPA's National Dioxin Study.
A bird study in 1986 should have spurred action by state and federal
officials. Deformities found in area birds were indicitive of dioxin and PCB

Dow continued to delay clean-up in the community by spending millions of
dollars on public relations, lobbying state and federal officials, funding
phony science, and publishing papers on dioxin that had little to do with
real science. The real science on dioxin in the early seventies was clear.
Dioxin caused multigenerational reproductive effects at tiny doses (1 ppt).
The list of other adverse health effects was growing.
Dow (knowing different) lied and said that dioxin only caused a 'rash'
called chloracne (Dow President, Paul Orrefice, 1983).

MDEQ sampling in the nineties again discovered that Midland soils were still
highly contaminated with dioxins. Dow again downplayed this information,
captured the more than business-friendly director of MDEQ, Russell Harding.
With the help of Russ and Midland City officials Dow managed to keep MDEQ
staff from further sampling, causing more delays and inevitably more
exposure for Midland residents.

Dow publically released a flawed worker study suggesting that dioxin had not
harmed their workers. Activists found discrepencies in the study and Dow
admitted there were excess cancers. The media never corrected this
publically. To this day the study has not been peer reviewed yet Dow
continues to use the study to convince the public that dioxin is not
causing harm.

Dow (with Harding's help) tried to get the state to change the state 201
residential clean-up standard. Changing the numbers would mean that Dow
would not have to clean up Midland soils. Local and state activists worked
tirelessly to expose these efforts.

Next, Dow hired Dennis Paustenbach to create further delays. Dennis is a
favorite scientist used by some of the country's worst polluters. With
Paustenbach and Harding's help Dow created further delays and confusion.
Paustenbach suggested that the state use a complicated risk assessment and
presented a flawed study suggesting that dioxin wasn't fully absorbed and
that you'd have 'to eat the dirt'to get enough dioxin to cause harm. More

Those are just some of the highlights.

Enough delays and band-aid fixes.
This is a serious public health issue and should be treated accordingly.

Post the Midland parks and schools where dioxin was found.

The DEQ and state health department also need to get educational literature
on dioxin to all Midland schools warning them of the real risks. This
literature should be sent home to parents.
Midland residents have been misinformed about dioxin and need to be
reeducated using credible and current scientific information on dioxin.
I would suggest using EPA scientist Linda Birnbaum's presentation. Dr.
Birnbaum made a presention at Dow on dioin's health effects and Dow was
unable to refute the studies.

Dow needs to quantify the amount of dioxin (and other PBT's) escaping from
their plant site. This should be a comprehensive study that identifies any
process or product that contains dioxin.Dow has not been forced to prove
that there are no other dioxin sources.
One example is Dow's herbicide 2,4-D that is known to contain dioxin. This
product is widely used by Consumers on lawns and a farmer's favorite.
I believe there are other sources. Dow should be forced to prove
conclusively there are no other ongoing dioxin sources. This should be peer
reviewed by independent and government scientists.

Test local wildlife and domestic animals living in the city of Midland.
Good indicator of resident's exposure.

Evaluate the risks from all chemicals released in Midland.
Releases of many highly toxic chemicals are routine in the city of Midland.
Both Dow Chemical and Dow Corning have had releases that have kept residents
penned in their homes. Fugitive emissions and 'accidental' chemical releases
are a way of life in Midland. The risks from these releases has never been
fully evaluated.
Add the risk from dioxins in soil and a different picture emerges.

We need a multi-media assessment that evaluates all routes of exposure.
How many toxic chemicals do Midland residents inhale or ingest on a
'typical' day?

CLEAN IT UP DOW. Continued delays mean continued exposure for Midland

Local Dow cheerleaders should not be allowed to decide the future of our
children. This is a public health issue, not a popularity contest.

I would also like to ask that some of my comments made on the ATSDR/MDCH
Health Consultation and verbal comments given to MDEQ staff be considered.
Time is limited and my work schedule does not allow me to submitmore
comprehensive comments at this time.

Diane Hebert
Midland, Michigan

For additional articles like this one, go to the Tittabawasse River Watch web site for complete coverage of the Tittabawassee River Dow Chemical dioxin contamination saga. . 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.