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Diane Hebert  1/15/03

DOW MYTH...1 ppb dioxin "Safe Level"

There are many misleading statements in Dow's recent press information
packet on dioxin. This packet was also distributed to Dow employees.

One of these myths has been to use the clean up standard of 1 part per
billion and call it "safe" or protective of public health.
This is not true or accurate information.
Unfortunately the media and some of the local health officials have repeated
this myth without investigating the history or the current science.

In fact, as far back as 1979 during the 2,4,5-T cancellation hearings,
scientist George Streisinger from the National Academy of Sciences testified
that levels as low as 1 ppt were able to produce multi- generational
reproductive effects. This number was largely was based on a Dow rat study.
Throughout the years as the dioxin problem grew and industry influence and
lobbying often prevailed, the number slowly but surely inched upward while
the EPA tried to figure out what to do with all of the emerging dioxin
sites.
Encouraged by heavy industry lobbying, agency Risk Assessments were tempered
with "Risk Management" decisions. We were told that this was a balance
between environmental, public health and economic concerns.
We get the risk, the polluter gets the economic reward (My take).

Currently Dow seems to be continuing to spin the dioxin numbers upward,
suggesting the local dioxin levels do not pose a risk.
Local media, elected officials and the public continue to hear AND SOMETIMES
REPEAT AS FACT that 1 part per billion is the a safe level. It is important
to know how and why 1 part per billion was selected.

HISTORY

CDC SAYS 1 PPB DIOXIN STANDARD NOT CONCRETE

Midland Daily News
January 24,1984

Atlanta (AP)

The National Centers for Disease Control (CDC) which warned Missouri
residents that dioxin levels of more than one part per billion in their soil
could be hazardous, said Thursday that level "SHOULD NOT BE VIEWED AS A
UNIVERSAL STANDARD."

In its Morbidity and Mortality Weekly Report, the CDC said adequate human
test data on the effects of dioxin is not available and exposure to
chemicals in soil is especially difficult to study.
The federal health agency issued Thursdays elaboration on its dioxin warning
to "explain why we did what we did what we did," said Dr. Renate Kimbrough,
a researcher at CDC.

The CDC, after the Missouri story was widely reported in 1982, advised
officials in that state that if the dioxin- formally 2,3,7,8-TCDD is present
in soils in quantities greater than one part per billion, it would result in
an unreasonable health risk to human health.

BECAUSE OF THE VARIABLES INVOLVED IN MEASURING EXPOSURE TO CHEMICALS IN
SOIL, THE ONE PART PER BILLION ESTIMATE IS SIMPLY THAT - THE BEST POSSIBLE
ESTIMATE, RESEARCHERS SAID.

"To err on the side of public safety, these assumptions should be
conservative" and should address factors like how much people are exposed to
dioxin-laced soil and how frequent, the CDC said.
Ms. Kimbrough said the one part per billion one is a conservative one.

"The CDC said it should not be viewed as a universal standard but rather as
an operational starting point to analyze each situation."

"The emphasis is on the uncertainties you have to deal with when you market
these kinds of judgement," Ms. kimbrough said.
"Sometimes that's not really clear to the public."End

WHAT THEY WEREN'T TELLING PEOPLE AT THE TIME.

There was an internal EPA Chlorinated Dioxins Workgroup formed during the
Agent Orange controversy.
This group of scientists met on a regular basis to discuss and make
recommendations on dioxin. Information from these meetings wasn't reported
to the public, nor were their concerns about the widespread dioxin
contamination throughout the country.
Bioaccumulation studies for dioxin were done in different parts of the
country on almost every critter. Many of these animals lived in areas where
dioxin-contaminated herbicides, primarily 2,4,-5-T and 2,4-D were used.
Dioxin was found in the tissues most of the animals living in
dioxin-contaminated soils. Also not reported to the public.

The more the dioxin group studied dioxin, the worse it got.
Internal discussions and studies were piling up and showing that at the
lowest levels found dioxin was capable of causing certain adverse health
effects.
This information wasn't reported to the public.

As more dioxin-contaminated sites emerged, the politics and secrecy within
the agency regarding these findings increased.
The magnitude of the problem, the potential liability and clean-up costs and
the exquisite toxicity of dioxin was mind boggling.
Industry began to play a larger role by influencing agency decisionmaking.
The actual scientific risk assessments that suggested harm from dioxin at
the lowest levels tested (1 ppt) were replaced with "Risk Management"
decisionmaking.

The 1 part per billion number was selected as an "interim number" until the
agencies could figure out what to do with such a huge and widespread
problem.
Throughout the years, industry has tried to use this number to suggest that
1 ppb is a "Safe Level."
The sciences never has and still does not support that high number.

Since the eighties we have learned even more about the effects of dioxin and
the news just keeps getting worse.

RECENT FINDINGS OF DIOXINS' EFFECTS IN PEOPLE

CARDIOVASCULAR DISEASE, DIABETES, CANCER, PORPHYRIA, ENDOMEETRIOSIS,
DECREASED TESTOSTERONE, IMMUNOTOXICIT.

DEVELOPMENTAL
THYROID STATUS, IMMUNE STATUS, NEUROBEHAVIOR, COGNITION, DENTITION, ALTERED
SEX RATIO, DELAYED BREAST DEVELOPMENT
( Birnbaum, Linda, Ph.D, EPA Director of Experimental Toxicology Division).

I am concerned about the lack of transparency in the current science
surrounding dioxin, especially at a local level.
Local health officials have not taken the time to thoroughly research the
public health issues surrounding this chemical.
In some cases they have accepted and adopted Dow's version of dioxin risks
and worse, passed this information on to the public.
The industry friendly Engler/Harding administration allowed these dangerous
myths to persist. Consequently, local residents have not been adequately
warned about the real risks of dioxin exposure.
There have been no real efforts to protect citizens from these risks. Dow
has even prevented the agencies from further community dioxin sampling to
fully assess all of the exposure pathways (BEYOND JUST SOILS).

CURRENT DOW SPIN-

SITE SPECIFIC ACTION LEVEL MORE STRINGENT THAN FEDERAL STANDARDS

THE SITE-SPECIFIC ACTION LEVEL RELATED TO DIOXIN HAS BEEN PROPOSED IN THE
CONSENT ORDER AT 831 PPT FOR MIDLAND RESIDENTIAL SOILS. THIS LEVEL IS BASED
ON SITE-SPECIFIC ASSUMPTIONS THAT MORE REALISTICALLY REFLECT ACTUAL EXPOSURE
CONSITIONS. THE SITE-SPECIFIC ACTION LEVEL OF 831 PPT IS MORE STRINGENT THAN
THE 1,000 PPT LEVEL THAT THE EPA CONSIDERS PROTECTIVE FOR RESIDENTIAL AREAS.
SIMILARLY, THE ATSDR USES 1000 PPT AS THEIR "ACTION LEVEL" FOR RESIDENTIAL
AREAS.
( Excerpt from recent Dow press packet).


According to a paper written by consultant Joel Hirshhorn, ATSDR scientists
reached conclusions similar to EPA scientists, especially after reviewing
the long list of non cancer effects, usually not noted by Dow and industry
scientists.
ATSDR scientists concluded "NO ABSOLUTELY SAFE EXPOSURE I.E, ABOVE ZERO CAN
BE IDENTIFIED."

1995: The ATSDR Public Health Assessment for Escambia Superfund cite cited A
50 PPT LEVEL FOR NON CANCER EFFECTS.

1995: ATSDR SCIENTISTS PUBLISHED A PAPER SUPPORTING 40 PPT DIOXIN SOIL CLEAN
UP LEVEL BECAUSE OF NONCANCER EFFECTS.

1996: EPA USED 200 PPT DIOXIN CLEAN UP LEVEL FOR RESIDENTIAL EXPOSURE AT TWO
SUPERFUND SITES, ACKNOWLEDGED AS A 10-6 CANCER RISK LEVEL.

1996: EPA REGION 4 ANALYSIS FOUND 79% OF SUPERFUND CLEANUP DECISIONS USED 1
PPB OR GREATER, BUT 9% USED LEVELS IN THE 4-7PPT RANGE.


BACKGROUND LEVELS AND INCREMENTAL EXPOSURES:

The issue of prior exposure is extremely important, although often
overlooked in cleanup decisionmaking. Sherman has noted that dioxins "RESULT
IN GREATER TOXICITY FROM REPEATED SMALL DOSES THAN FROM A SINGLE DOSE,
BECAUSE OF INDUCTION OF ENZYME SYSTEMS, CHANGES IN IMMUNOLOGICAL FUNCTIONS,
AND LONG RETENTION TIMES WITHIN THE BODY."
( March 1997,Hirshhorn, Joel, Clean Up Levels For Dioxin Contaminated
Soils).

I think we should demand more from our local health officials who have
clearly not taken the time to examine the current or past science on dioxin.

We need public education and protection that is real, not industry-driven.
We need further dioxin sampling to determine all of the exposure pathways
and to identify sites and dioxin levels that have not yet been identified.
WE NEED PUBLIC HEALTH PROTECTION ASAP (INTERIM REMEDIAL ACTION).

Dow would like to close the book now and severely limit the dioxins to
exposure to ONLY soils, ignoring other significant pathways,and use an
industry paid scientists unpublished study to suggest this exposure and risk
is minimal.
Their motives are clear.
Their science is flawed and does not reflect real risks associated with
dioxin exposure.

I hope this information proves useful for educating local health officials
and the public, who must learn to sort out fact from fiction and slick
public relations.

Diane Hebert
Midland

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