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3/10/03 Michelle Hurd Riddick response to Commissioner Kahn's Comments

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To follow up on Commissioner Kahn's comments about the county's position on the contamination of the  T-River floodplain. Because of the previous political environment an open honest discussion about dioxin has not occurred at the local level. Independent sources sharing independent findings on the chronic low dose exposure to dioxin on human populations have been missing. Contrary to Dow's statements, dioxin is one of the most studied chemicals to date.  EPA will not ascribe a "safe level" for exposure. The precautionary principle of public health is being ignored in Saginaw County and in Midland County. Welcome to the arena of " all politics is local". Honest debate needs to take place. It is disingenuous and criminal for Dow to state that dioxin is only a problem when ingested. Again, the weight of scientific evidence supports dioxin to be toxic in small amounts. (See Dr. Linda Birnbaum, EPA below)   Clean air, water and safe use of the land should be a given when one purchases home property or visits a public park. Dow's attempts to downplay the toxicity of dioxin with slick public relations; feigned concern for public health and distortions is unethical. Dow needs to be placed under the microscope of scrutiny. Dow's discharges, regardless of when they occurred do not mitigate or diminish the health threat they pose to the people.   In reality it is difficult for many  to scrutinize a leviathan of the corporate 500-club especially in when it resides in one's back yard.

Saginaw County Health Department came out early and incorrectly in support of the Dow funded Health Study. Volumes of highly critical comments from ATSDR, EPA, DEQ, and DCH were released on the Dow Health study and the accompanying bioavailability study that tied clean up to human exposure. In the end the only support for the health study was DOW and the two local health departments. WHY? ……………….
As Commissioner Kahn pointed out, the county still supports an exposure and health study.   However, it must be one that takes into account the critical analysis from the above agencies. That means the county must position itself to think independent of any influence from Dow. We'll see.

Why is the study being proposed? What will be done with the results? What remedies are intended? Does the study have the power to show a statistical and significant difference? If the power is not there, then the outcome can be predicted to serve the interests of Dow. How will levels be measured and how will they be treated in the aggregate? Health effects attributable to dioxin are numerous and do not carry dioxin specific fingerprints. Questions of design, interpretation have never been answered. Saginaw County must not accept any study without answers to these and numerous other concerns. As someone once said, " once you start down that road of acceptance, before addressing interpretation and design, the train has left the station and Dow will  manipulate the process   from there." 

This Health study remains premature and questionable. In the meantime we must go back to the basics and focus on the following:

Process for public participation …………DEQ DCH and ATSDR need to move on it!

Compellation of the comments on the MDCH Health Consultations

Phase three Sampling by DEQ of residential properties

Full characterization and fingerprinting of the dioxin sources

Define the extent of the contamination

Implementation of interim health measures to protect the public health

Structure of a public health registry

As we remain engaged we must never forget that these pieces of property, public and private belong to the people as do all the resources of this watershed. We are all responsible to each other to do this right. Dow has no right to trespass with their dioxin on our communities or our bodies. Collectively, we will find our voices and we will be heard. I know many of the members of the Board of Commissioners and I know them to be a decent body of men and women willing to listen. So let's start talking. Much appreciation to Commissioner Kahn for his update and response.

Michelle Hurd Riddick
Lone Tree Council

Ref: Dr. Linda Birnbaum 'Re-evaluation of Dioxin' Presentation to the
102nd Meeting of the Great Lakes Water Quality Board, Chicago, Illinois,
July 15th 1993. ToxCat Vol. 2 No. 8

On whether there is a threshold for dioxin Dr. Birnbaum said;
"there is no threshold for immunotoxic responses to dioxin."
In other words, no level of dioxin below which the immune system is not
affected. There is no "safe dose," any amount seems to do some damage,
at least in animals.

Human studies
Industrialists have maintained humans are not as sensitive as
animals to dioxin. Research shows this is not strictly true. Dr.
Birnbaum stated; "...with respect to dioxin, people react similarly to animal
responses ...there is a large amount of data showing for example, that
changes in bio-chemical properties such as enzyme induction in some
hormonal states and in growth factors, occur at similar body burdens in
animals as they do in people." For example, in the on-going occupational
study conducted by National Institute of Occupational Safety and Health
(NIOSH) looking at workers who were exposed to dioxin, these adult males
are showing decreases in the levels of their circulating testosterone at
body burdens very similar to the body burdens in adult rats. In
immunotoxicity testing, human lymphocytes and cultured cells respond to
the same concentration of dioxin in the media as mouse and monkey cells.
In terms of developmental toxicity based on organ culture you find
similar responses at similar concentrations of TCDD. For example, if you
take out the embryonic palate of a rat and the embryonic palate of a
human, put them in culture and expose them to the same concentration in
the media, you get a similar response. Similarly, the body burden
associated with chloracne in people is essentially the same as the body burden
causing chloracne in monkeys, in hairless mice, or in rabbit cars. Animals with a
lot of hair -- like regular mice and regular rats -- do not develop chloracne, but hairless
mice do and the body burden there is essentially the same. Cancer appears to
occur at similar body burdens in animals as in humans.[5]

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