Dow’s The Dow Chemical Company’s

DEQ Analysis of Wild gGame From Tittabawassee River Flood Plain

Wild Game Dioxin Study Results Cause for Concern

 

The Michigan Departments of Environmental Quality (MDEQ), Agriculture, Community Health, and Natural Resources areis concerned with the elevated dioxin levels in wild game living in the floodplain along the Tittabawassee River downstream of Midland presented that have been reported in from a study conducted for The Dow Chemical Company’s (Dow’s Study) draft study report of wild game living in the floodplain along the Tittabawassee River.. These elevated levels of dioxin could result in increased health risks for people who eat game harvested from this area. Information about the increased risks and tThe area of concern is shown in the attached mapis being evaluated by the Michigan Department of Community Health (MDCH), the Michigan Department of Natural Resources (MDNR), and the Michigan Department of Agriculture (MDA), and will be published as soon as that information is available. .

The Dow Study was conducted as a requirementpart of the corrective action program that Dow is required to conduct under state and federal law.

Samples of deer muscle and liver, turkey, and squirrel were taken in two areas in the floodplain downstream of Midland and at a comparison location upstream of Midland. The downstream study areas are located near Smith’s Crossing (about 4 miles downstream of Dow) and near Imerman Memorial Park (about 13 miles downstream of Dow).

Levels of dioxinsdioxin in the wild game harvested in the floodplain downstream of Midland are higher than levels found in game harvested from a location upstream of Midland (2 to 120 times higher). Typically, the highest concentrations were seen in the samples collected near Imerman Memorial Park.

The study only tested for dioxin levels in Only deer, turkey and squirrel harvested from the Tittabawassee River flood plain have been tested for dioxin. The Michigan Department of Community Health has issued health advisories for consuming wild game based on the dioxin levels found in these animals at the locations downstream of Midland. Other wild game may also contain dioxin at levels that are a concern and other downstream areas may be affected.

Until more information is available, the MDEQ offers this general advice to reduce exposure to dioxin in wild game:

Choose lean wild game species

Trim any visible fat from the meat before cooking

Do not eat organ meat such as liver or brains

Do not eat the skin

Deer

Muscle

Deer

Liver

Turkey

Meat

Squirrel

Muscle

Avg

Min

Max

Avg

Min

Max

Avg

Min

Max

Avg

Min

Max

Upstream

Concentrations

0.067

0.036

0.169

0.572

0.224

1.26

0.181

0.107

0.388

0.071

0.040

0.107

Smith's Crossing Concentrations

0.169

0.116

0.259

11.1

5.6

19.2

10.2

0.628

25.4

0.403

0.092

1.48

Smith's Crossing/ Upstream

2.5

3.2

1.5

19.3

25.0

15.2

56.7

5.9

65.5

5.7

2.3

13.8

Imerman

Concentrations

0.523

0.234

1.24

64.0

8.91

149

12.9

12.9

12.9

1.32

0.083

4.29

Imerman/

Upstream

7.9

6.5

7.3

111.8

39.8

118.3

71.4

120.6

33.2

18.6

2.1

40.1

Note: Highlighted values isrepresent the number of times higher the downstream concentration is compared to the upstream concentration. As an example for the average concentration in deer muscle at Smith's Crossing as compared to the Upstream location is:

 

Levels of dioxins in the wild game harvested in the floodplain downstream of Midland were higher than levels found in game harvested from a location upstream of Midland.

Levels of dioxins in some of the wild game harvested in the floodplain downstream of Midland were far higher than levels in store-bought foods studied by U.S. Food and Drug Administration (FDA). The FDA takes samples of store-bought foods that are available in the national food supply and tests them for various chemicals. In the most recent FDA studies (2001-2002), the range of dioxin levels in meat and poultry in the national food supply was 0.004 to 0.46 part per trillion (ppt).

The Michigan Department of Community Health (MDCH) is advising that hunters and their families follow these recommendations:

Turkey skin contained the highest levels of dioxins and it is likely that levels in turkey organ meat such as liver would also be high. Although MDCH advises that you not eat turkey taken from the floodplain, if you do eat this game remove the skin, and discard the liver and any other organ meat.

Only deer, turkey and squirrel harvested from the Tittabawassee River flood plain have been tested for dioxins. Other wild game may also contain dioxins at levels that are a concern and other downstream areas may be affected. Additional studies are being considered. Until more information is available, the MDCH offers this general advice to reduce exposure to dioxins in wild game:


For comparisioncomparison purposes, levels of dioxinsdioxin in some of the wild game harvested in the floodplain downstream of Midland were far higher than levels in store-bought foods studied by U.nited S.tates Food and Drug Administration (FDA). The FDA takes samples of store-bought foods that are available in the national food supply and tests them for various chemicals. In the most recent FDA studies (2001-2002), the range of dioxin levels in meat and poultry in the national food supply was 0.004 to 0.46 parts per trillion  (ppt). At the downstream sample locations, all of the deer liver samples (95.6--15049  ppt) and all of the turkey samples (0.6-25 ppt) are above this range. Some of the squirrel muscles samples (0.08-4.3 ppt) and deer muscle samples (0.12-1.2 ppt) are above this range. Bar graphs of this data, andincluding a comparisioncomparison to the national market basket concentrations, are presented as attachments to this summary.

The data indicates that these toxins are accumulating in land animals that are fairly low on the food chain. As these animals are eaten by their predators, further biomagnification (increased contamination of animals higher on the food chain) is expected. Additional ecological risk assessment work is needed to determine the significance of this contamination and to determine the level of cleanup necessary to protect the ecology of the Tittabawassee River as well as human health.

It is important to remember that

Average levels of dioxins in wild game should not be compared to the trigger level of 10 10 ppt for Michigan Fish Consumption Advisories, as was done ins some recent press reports on this issue.. Fish advisories are based on how much and how often a person will eat sport-caught fish, however . Tthis information is not available for wild game. The Michigan Department of Community Health advisories for consuming fish from the Tittabawassee River, Saginaw River and Saginaw Bay are found at http://www.michigan.gov/mdch/0,1607,7-132-2944-13110--,00.html.

Fish advisories for dioxin are not based on the average level of dioxins.

Instead, MDCH looks at how many fish in a sample exceed the 10 ppt value to decide whether a fish advisory is needed.

As a reminder, the Michigan Department of Community HealthDCH has issued Fish Consumption Advisories that remain in effect for sport sport-caught fish from the Tittabawassee River below Midland based on levels of dioxin and polychlorinated biphenyls.

United States Environmental Protection Agency (U.S. EPA) Desk Statement

On August 5, 2004, the U.S. EPA issued an "EPA Desk Statement on Dow Off-Site Contamination" (add link to DEQ website if desk statement is posted) thatwhich addresses this issue. This statement also indicates that there may be unacceptable risks to human health from contamination of the food chain. The EPA desk statement concludes that the wild game and other exposure pathways need to be considered when making dioxin cleanup decisions in Midland and the Tittabawassee River and Saginaw River watersheds.

Ecologic Implications

The Dow data has ecologic as well as human health implications. The terrestrial food chain downstream of Midland is contaminated with dioxins and furans well above the upstream comparison site with dioxins and furans, indicating that and these toxins are accumulating in land animals that are fairly low on the food chain. As these animals are eaten by their predators, further biomagnification (increased contamination of animals higher on the food chain) is expected. Further ecological risk assessment work is needed to determine the significance of this contamination and to determine the level of clean-up necessary to protect the ecology of the Tittabawassee River as well as human health.

Next Steps:

The MDEQ will continue to work with Dow Chemical and, the MDCH, the MDNR, the Michigan Departments of Community Health, AgricultureDAG and Natural Resources, and the U.S. EPA, and the United States Fish and Wildlife Servicesand other State and Federal agencies to provide updated accurate and unbiased public information to the public on this issue, plan and conduct additional investigations, and to address the soil and sediment contamination that has resulted in the contamination of these animals.