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TRW Archives 2006 3rd quarter 07/01/06 - 09/30/06

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09/19/06 Dangerous dioxin planned for inadequate floodplain dump

Lone Tree Council

P.O. 1251, Bay City, Michigan 48706

(Fighting for environmental justice since 1978)


PRESS RELEASE                      CONTACT:  Michelle Hurd Riddick (989) 799-3313

SEPTEMBER 19, 2006                                    Terry Miller (989) 686-6386

                                                                            Pat Bradt ( 989) 753-6036

Dangerous dioxin planned for inadequate floodplain dump

Government documents reveal Dow’s secret discussions with feds to circumvent proper disposal of toxic cleanup, use Army Corps’ navigational spoils facility instead


Dow Chemical Company plans to send dioxin from a toxic contamination site to a planned dredged materials storage facility alongside the Saginaw River that is not designed as a toxic waste disposal, according to Environmental Protection Agency documents made public through the Freedom of Information Act.


The documents show the Army Corps of Engineers has, discussed the plan with Dow without public scrutiny or input. The dredge facility, under construction in Zilwaukee and Frankenlust townships, is designed to store less contaminated sediments removed for navigational purposes. It is NOT designed to contain the highly dioxin-contaminated materials that Dow eventually must be removed from the Tittabawassee River, Saginaw River and Saginaw Bay.


“Toxic sludge should be disposed of in a licensed hazardous waste facility,” said Lone Tree Council Chairman Terry Miller. “Transferring it from the river bottom to the floodplain wouldn’t be a cleanup at all, but simply a rearranging of toxic sediment in a different part of the watershed. The idea that Dow is considering this, and that government regulators aren’t rejecting it out of hand, is outrageous.”


The documents were from the files of the Environmental Protection Agency’s Region V headquarter in Chicago, and obtained by the Lone Tree Council after a FOIA request.


They verify that Dow has negotiated with the Army Corps over plans to use the facility for toxic disposal and that the EPA has serious reservations about the dredge facility itself.


An April 2006 memo states:  “Negotiations are occurring between the Army Corp of Engineers and Dow concerning the potential use of by Dow of a planned ACOE dredged material disposal facility. Dow is seeking the option of potentially disposing of contaminated sediments from the Saginaw River in the DMDF as part of the future potential dredging by Dow.” (Gerry Phillips, Corrective Action Program Manager, US. EPA)

Lone Tree volunteer Michelle Hurd Riddick, who obtained the documentation from EPA’s Chicago headquarters, made clear the significance of the group’s discovery. 


“The lack of transparency and candor with the public and impacted communities is appalling,” said Hurd Riddick. “This unlined slurry pit sitting in the floodplain of the Saginaw River is not appropriate for the Corps’ contaminated river dredgings, let alone considering it for Dow’s cleanup.  The Saginaw County Board of Commissioners agreed to allow the taxpayers to accept liability for a navigational dredge disposal site – not a hazardous waste dump.  Commissioners were sold a bill of goods. Why are Saginaw taxpayers being asked to accept perpetual legal and financial responsibility for Dow’s contamination?”


Saginaw County is the local sponsor of the project, and the Saginaw County Commission, as part of its sponsorship, is required to accept financial responsibility for any problems associated with the site.


“The Corps should be working for us,” said Zilwaukee Township clerk, Pat Bradt, not Dow.  They should not be making backroom deals.  As it is, our property values are being lost, our quality of life destroyed, and now it looks like they want to shove a toxic dump site down our throats – can it get any worse!


This summer, Lone Tree Council filed suit in federal court arguing that the Corps should have conducted the more comprehensive Environmental Impact Statement required for federal projects that will have a significant environmental impact.  Lone Tree requested an injunction to stop the project until the proper analysis was done.  Although a Detroit federal judge denied the injunction, the case is continuing on the merits of requiring an EIS. 


The controversial project was a response to the problem of silt build-up in the Upper Saginaw River that was slowing ship passage in the channel.  Support for dredging remains strong in the community and Lone Tree Council has urged its use in a Dow cleanup – provided that dioxin-contaminated sediment is placed in a licensed hazardous waste landfill or treatment facility.   The haste in selection of the present location, however, has been controversial.  Officials of Zilwaukee and Frankenlust townships opposed what they saw as heavy-handed tactics by the Corps and Saginaw County to build the dump in violation of local zoning restrictions in a floodplain near residences.  Environmentalists argued the location was next to a state game preserve in a major wildfowl flyway, and without water treatment. 


The Corps has since agreed to emergency dredging of a critical turnaround basin with dredge spoils being placed in the Confined Disposal Facility (CDF) at the mouth of the Saginaw River. However, construction at the Zilwaukee/Frankenlust site has been underway through most of the summer.  The Corps’ intent is to begin dredging the Upper Saginaw River and placing those spoils in the new site as early as next summer, although the Corps has not made that clear.


Environmentalists have mounted a radio campaign that began September 18th with the goal of encouraging Saginaw County residents to contact their County Commissioners to reverse their support for the facility, and to relieve taxpayers of any liability.





April 6 2006 EPA Dow Hot Issue Document


September 27th 2005 Executive Committee Saginaw County Board of Commissioners assigning ownership of the DMDF to the taxpayers of Saginaw County


September 20th 2005 Letter from County Legal Council to the Board advising about the county’s liability for the DMDF


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09/06/06 EPA questions applicability of key dioxin study to Michigan cleanup

Lone Tree Council / TRW Dioxin Update
Risk Policy Report

September 5, 2006

EPA Region V is questioning the applicability of a recent landmark dioxin exposure study to a contentious dioxin cleanup near Dow Chemical Co.’s headquarters in Michigan, saying the study did not thoroughly target susceptible subpopulations and is not the type of information that forms the basis of remediation decisions.


University of Michigan scientists released preliminary results from the research, The University of Michigan Dioxin Exposure Study, last month, which showed residents in a dioxin-contaminated area near the Dow facility have higher levels of dioxin in their blood, but the study also found that age, weight and gender more greatly influenced those levels rather than a person’s proximity to the contaminated site.

While the researches did not draw any conclusions about health risks or cleanup policies, one of the authors said the study—which found the highest dioxin blood levels in older, heavier males—would provide “valuable data [to regulators and the community] in determining how best to manage this problem.”

Dow officials, who have long fought both Michigan and EPA proposed cleanup levels and efforts to demand extensive surveys of dioxin contamination stemming from the facility, cited the study as important information to take into account as EPA prepares a cleanup plan for the site. Dow’s Midland, MI, headquarters has dioxin levels as high as 2,000 parts per trillion (ppt), with an average of almost 1,000 ppt at the site. The site spread contamination to the Tittabawassee River, which has deposited contaminated sediments on the shores of the river via frequent flooding and continues to do so. The area along the river has farms and residences, among other uses.

EPA Region V officials, however, are raising a number of questions about the study, noting that its results are preliminary; that it did not specifically target susceptible populations like children, hunters, fishermen and pregnant and nursing women; and that it is not the type of health effects study that could be used to determine health risks from exposure to the contamination.

Moreover, EPA says that because background levels of dioxin—a suspected carcinogen—found in human blood are high enough to pose health risks, the elevated levels found in the study are of concern, since residents near the Dow site had 28 percent higher dioxin levels than the control group. “EPA is concerned about the dioxin blood levels in some local residents,” one Region V source says, since “a number of studies have confirmed a relationship between background levels [of dioxin in humans] and adverse health effects” such as diabetes, endometriosis, thyroid disorders, immune disorders and neurological impairments.

The source also says EPA is concerned about highly exposed subpopulations, like hunters and fishermen, who consume a significant amount of dioxin-contaminated fish and game. “There wasn’t an attempt upfront to include highly exposed groups,” one EPA source says. Another regional source notes that both subsistence fishermen from environmental justice populations along with recreational fishermen and hunters get a significant portion of their protein intake from fish and game in the area, which are likely to be contaminated with dioxin. The first EPA source also notes that the study only evaluated people over age 18, excluding infants, children and pregnant or nursing women, who would be considered at higher risk than the populations studied.

The second EPA source adds that the Michigan study would only be one of many types of information the agency will consider as it develops its cleanup plan, but it will not be a major factor because it does not draw any conclusions about health. To do so, EPA will develop a risk assessment and combine that information with data that are currently being collected and will be collected over the next few years on levels of contamination in the flood plain near the Dow facility.

Dow is currently collecting samples along the first six miles of the Tittabawassee River and will do more sampling over the next several years based on the results of the initial sampling. EPA says its remedial options include removing contaminants if there are “hotspots,” but if contamination is spread evenly, that would make cleanup more difficult.

Remember it is the responsibility of MDEQ and MDCH to act or require interventions and cleanup before health effects occur. That we should  look for dead bodies or disease before we act is irresponsible.


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08/16/06  U of M Dioxin Exposure study results for Joe "Median"

The U of M public presentation last night was probably very useful to Dow and the one person whose dioxin blood level happened to be in the exact middle (the "median") of the other 945 people who had their blood tested.  Statistics are a wonderful tool and can be used to present or skew data in ways that boggle the mind. For reasons unknown, the U of M choose to use the "Median" dioxin blood level for all of it's presentation.  Unfortunately for the public, this tool effectively diverted attention from the real fact that 50% (472) of the people tested had levels higher than the studies median (which is 28% higher than those in the rest of the nation).

The presenter provide a little insight into his suspected reasons for 8 of the high outliers.  Discounting the 8 as he did, the remaining 465 people had levels higher than poor "Joe Median".   What do the 50% of  people on the high end of the scale have in their bodies;  30% more, 50% more, 100% more, 1000%....?   If I where Joe, having "28%" more of the most deadly toxin know to man would be a concern.  Especially when Dr. Birnbaum of the EPA says they are observing adverse health effects on humans at "background" levels. The ATSDR/MDCH pilot exposure study performed a few years ago on floodplain residents used "percentiles" to explain the results.  We submitted a question to Dr. Garabrant at the meeting asking why percentiles where not used in his presentation, however it was ignored.  Mission accomplished Dr. Garabrant, the public was placated. Was this statistical slight of hand a first of many payments to Dow to recoup it's $15,000,000? 

This was a preliminary report, the U of M say more analysis will follow.  Visit the U of M dioxin study web site for additional details and maybe you can find the answer.  Click here for local media coverage.

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08/15/06  U of M Dioxin Exposure study results released today
The University of Michigan is staged to release the results of it's $15,000,0000 Dow funded Dioxin Exposure study.

bullet 09:00 A.M. Press Release, Midland Ashland Court Hotel
bullet10:00 A.M.  Results available on-line at
bullet06:00 P.M.  Public community meeting, Conference & Event Center at Curtis Hall, Saginaw Valley State University.

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08/06/06  Looking for more than words; it's time for action

    On May 13, 2006, the News carried a front-page story by Kathie Marchlewski entitled "Environmentalists encouraged by Dow plan."

    The context was the May Dow/DEQ meeting informing the public of progress on the Tittabawassee River floodplain cleanup. As the summer wears down, and another public meeting is about to take place, the gentle reader must allow me a bit of a rant. I was the unfortunate source of that optimism.

    Before the week was out and the ink was dry on that story, Dow was challenging the Michigan Department of Public Health's risk numbers -- and my optimism was morphing again into cynicism.

    It is absolutely frustrating.

    It has been five years since the discovery of elevated levels of dioxin in the Tittabawassee floodplain, and nearly eight years since continued elevated levels uncovered in Midland.

    To date the extent of the contamination in Midland remains unmapped as does the extent in the floodplain and Saginaw River. The Company has repeatedly submitted inadequate plans to the DEQ. From what we have heard since the May meeting, Dow and the State are not in agreement as to what level of dioxins should be left in the soil or sediment.

    We are talking about chemical trespass here folks, why should there be a debate? Residents did not ask for dioxin in their backyards. Nor should they be expected to live with some compromised dioxin number different from background.

    In addition, the Company continues to contest dioxin's toxicity, question its bioavailability, and support legislative efforts to compromise cleanup levels. In a word, it continues to evade responsibility.

    But it does talk a good game. Dow has launched a multi-million dollar ad effort: The "Human Element campaign."

    According to Patti Temple Rocks, Dow vice president of global communications: "This is more than an ad campaign to our company. It is a statement to the world and, more importantly, to ourselves about the future direction of our business ... it reflects our intention as a company to prioritize the things we do to advance innovation and focus the people and resources of Dow on solving human problems."


    Anyone who has scanned a magazine in a dentist's or doctor's office will have seen one of Dow's Human Element "faces." I too have seen a Dow face - in the anger, the violation, the futility of residents of the Tittabawassee floodplain who find themselves four years into a process that at best remains uncertain.

    What is the real Dow? Have they turned the corner, intent on "solving human problems?" If, as the bard noted, the past is prologue, the company's past is a clue to its future, and its past has not been directed at solutions.

    Dow's foot-dragging, its meeting the state behind closed doors, its questioning of dioxin's toxicity, in the face of overwhelming academic research (and the last report from the National Academy of Science) is an approach as old as corporate irresponsibility. It even has a name, it is referred to as manufacturing uncertainty.

    Though most identified with the tobacco industry, other corporations opposed to public health cleanups or environmental regulations have used the same tactic. Manufactured uncertainty was explained in The American Journal of Public Health (July 2005) as a company's questioning of the validity of scientific evidence and ridiculing research that threatens their interests. Its purpose is to sow ambiguity in peoples' minds, to deflect regulatory pressure and to retard actions that cost the company money. As noted, the tobacco industry and the lead industry used it for years. The chemical lobby, particularly the Chlorine Council, has effectively used Washington lobbyists to delay release of the national dioxin reassessment for fifteen years. Dow has used "spin" on its animal research and questioned the state at every step of the remediation process. That is Dow's past.

    Will the August meeting disclose a new Dow -- will they become cooperative and committed to an expedited clean up of their community?

    In May, its spokesperson told the public that the Company couldn't complete a local dioxin cleanup until 2017 -- 11 years from now. A child born today would be in middle school before a cleanup was completed. That is not acceptable. It is time to call on Dow to "prioritize" and "focus" at home -- quit arguing and simply act -- a far better testimonial to its commitment than fine sounding words. But "focus" and "prioritize" are too vague -- the d company has to commit to removing its dioxin to background levels -- 8 to 10 ppt -- and begin now, yesterday -- anything less is simply hypocrisy.

    Terry Miller is executive director of the Lone Tree Council.

    Editor's note: Dow and the Michigan Department of Environmental Quality are hosting a community meeting Wednesday at the Horizon's Conference Center, 6200 State St., Saginaw, beginning at 6 p.m. Staff from Dow, DEQ the Michigan Department of Community Health will be available for discussion/questions beginning at 5:30 p.m. and for one half hour after the meeting.

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  Politicians Misuse Federal 1000 ppt Dioxin "Action" Level, ATSDR concurs

Lone Tree Council

P.O. 1251, Bay City, Michigan 48706(Fighting for environmental justice since 1978)



Misuse of Federal 1000 ppt Dioxin Level Increases Exposure, Benefits Dow

State representatives should stop misusing a federal 'action level' not designed for setting cleanup standards for the highly toxic chemical dioxin, charged several environmental organizations. 

Groups released a letter today from Howard Frumkin, Director of the National Center for Environmental Health (NCEH) and the Agency for Toxic Substances and Disease Registry (ATSDR).  The letter was sent in response to a request from environmental organizations for clarification on the ATSDR number, often referenced by Midland-area legislators seeking to weaken Michigan’s dioxin cleanup number. The letter states in part: "...the concept of an ‘Action Level’ for dioxins in soils has sometimes been misunderstood."  The letter directly comments on the use of the1,000 ppt standard in proposed legislation in Michigan.  It states:

July 25 th, 2006 Michelle Hurd Riddick, 989-799-3313

Terry Miller, 989-686-6386

Tracey Easthope 734-761-3186 x 109

Kathy Henry 989-695-5348

<>"The ‘Action Level’ was intended to trigger consideration of various public health actions.   It was not intended either to define the need for remediation or to serve as a threshold below which there is no public health concern.  The appropriate application of the policy guideline is to compare site-specific data to the 50 ppt screening level, not the 1,000 ppt Action Level, to determine the need for further evaluation."  


Representatives from the mid Michigan area have repeatedly proposed legislation referring to the federal 'Action Level' as a cleanup standard.  This should make clear that that practice is not supported by the intention of the ATSDR's 'Action Level'. The letter goes on to say,As you cited in your letter, we understand that certain Michigan state legislators have been referring to our Action Level in proposed legislation to modify the state cleanup for dioxins in soil. This is an example of how our guidelines have been applied in ways that we did not intend."

"What many elected officials have attempted to do is absolve Dow Chemical for contaminating an entire region with dangerous levels of dioxin.  Raising the "safe" level to a non-existent federal level is shameful," said Tittabawassee River resident Kathy Henry.  

"This should put an end to the continued misuse of the ATSDR 'Action Level' by Representative Moolenaar and other legislators who have tried to confuse the public," said Michelle Hurd Riddick of the Lone Tree Council.  "This kind of misrepresentation does not serve the public interest.  It just means more delays, more exposure, and more risk for the public while we should be moving forward with a real cleanup that is protective of public health.  We can't legislate this problem away."

Environmental and community groups that have opposed attempts to weaken that state's protective standard for dioxin in soils include the Lone Tree Council, the Ecology Center, the Michigan Environmental Council, Environment Michigan, the Sierra Club, Clean Water Action, and Tittabawassee River Watch.


bulletEnvironmental Groups letter to ATSDR requesting discontinuing referencing 1000 ppt"Action" level
bulletDr. Frumkin's response
bulletNews article: MDN Dioxin Legislation Opposed 042506
bulletLone Tree Press Release pdf format

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  Lone Tree/TRW Dioxin Update

bulletNational Academy releases report on the Dioxin Reassessment
bulletThe National Academies panel said at a briefing that the EPA's recommended standards -- which are as much as 10 times more stringent than the current ones -- should be applied within a year or so, with no further data-gathering required.

"We're clearing the way for EPA to release this report," said panel chairman David Eaton, a professor at the University of Washington, Seattle. "Our recommendation is not to go back and start over." 

One of the most articulate summaries of the NAS report was done by Dave Lindhardt of ChemTelligence Inc. Dave is a retired Dow chemical engineer and we much appreciate his willingness to share it with us.  Visit his web site or  access his summary at the following link:
bulletThe Dioxin Slurry Pit Progresses
bulletWith DEQ's blessing construction of this site is proceeding absent a construction plan or an operational management plan. Nothing can go into the site until the OMP is approved but wouldn't you think how the site is constructed is paramount to how the contaminated sediments are managed? Politics trumps science, planning and process every time. Wouldn't be the first time a corporation was successful in passing off a significant portion of their cleanup liability to the taxpayers
bulletRiver remains toxic, but not quite as bad
bulletThe Saginaw News report  goes on to say concentrations of 8, 000 + are found in the Tittabawassee River. That is old data. Dow found 23,000 ppt near the W. Michigan Park and the banks of the river near Imerman Park top out near 20,000 ppt. The Saginaw River has concentrations as high as 16,000 ppt
bulletDow receives EPA citation
bulletEPA also filed a complaint against Dow for failing to comply with the Emergency Planning and Community Right-to-Know Act. This from the company who has launched a multi million dollar Human Element ad campaign announcing its "vision of addressing some of the most pressing economic, social, and environmental concerns facing the global community in the coming decade."
bulletMDCH Community Event
bulletThis Thursday from 9am to 1pm in Morley Plaza Downtown Saginaw Michigan Department of Community Health will be hosting activities for the public to answer questions about safe fishing, fish consumption and the fish advisories on our local rivers and Bay. Please plan on attending.  If you have questions please call Kory Groetsch at MDCH 517-335-9935 or
bullet10,000 EPA Scientists Protest Library Closures
bulletIn an extraordinary letter of protest, representatives for 10,000 U.S. Environmental Protection Agency scientists are asking Congress to stop the Bush administration from closing the agency’s network of technical research libraries.

Click here for the entire update with much more detail.

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7/16/06 NAS  Dioxin Review: Panel clears way for tougher cleanup of dioxin

Since the release of the NAS dioxin review on 7/11/06, both sides of the battle have been pumping out media spin articles, the following points recap (Reuters article)  what needs to be done to protect public health now that the NAS review of the EPA's dioxin reassessment study is complete:

bullet"The cancer-causing chemical dioxin ... should be cleaned up to a new, much higher standard"
bullet "dioxin causes cancer and reproductive and immune-system disorders in humans."
bullet"EPA's recommended standards -- which are as much as 10 times more stringent than the current ones -- should be applied within a year or so, with no further data-gathering required.
bullet "Our recommendation is not to go back and start over."
bullet"industries that use chlorine of stalling enforcement of higher cleanup standards.
bullet Enough is enough. Let's get on with establishing health protective regulations."

Copies of the report, titled "Health Risks from Dioxin and Related Compounds: Evaluation of the EPA Reassessment," are available by calling the National Academies Press at (202) 334-3313 or 1-800-624-6242 or on the Internet at
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7/11/06 Federal Review:  Yes, Dioxin is still toxic!

 For Immediate Release

July 10, 2006

Tracey Easthope, The Ecology Center: 734-761-3186 x109
Michelle Hurd-Riddick, Lone Tree Council: 989-799-3313
Terry Miller, Lone Tree Council: 989-686-6386
Dr. Michael Harbut, Environmental Medicine: 248-506-8871

Local experts: Dow’s dioxin must be cleansed from tainted watershed

 Dioxin, a chemical released for decades by Midland-based Dow Chemical Co. into the Saginaw Bay watershed is toxic. It threatens the immune system, and can cause thyroid dysfunction, lipid disorders, neurotoxicity, cardiovascular disease, and metabolic disorders. It can cause cancer. Even small concentrations over time can build up in human beings and threaten health.

 All those conclusions, reached years ago by scientists and the Environmental Protection Agency, were reaffirmed in a National Academies review of the proposed EPA Dioxin Reassessment that was released today.

 “The review is yet another piece of science strengthening the call for cleanup of the riverbanks and riverbeds downstream from Midland,” said Terry Miller of the Bay City-based Lone Tree Council.

 Dioxin pollution in parts of the watershed is dozens of times higher than safe levels, and has prompted public health warnings on human consumption of both fish and terrestrial wildlife from the region.

 The new review does nothing to change that: “Dioxin is still dangerous,” said Dr. Michael Harbut, a Royal Oak-based expert in environmental health. “Most informed physicians and scientists believe it causes cancer and a host of other serious health problems in humans, especially in unborn babies who are the most vulnerable.”

 Federal regulators should now complete the reassessment: “The review paves the way for the EPA to finish its report, which has taken 15 years already,” said Tracey Easthope of the Ann Arbor-based Ecology Center. “Even the National Academies are now urging the EPA to finalize the report.”

 Hugh McDiarmid Jr.
Communications Director
Michigan Environmental Council

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7/11/06 National Academies New Study Concludes Dioxin is Toxic

Center for Health, Environment and Justice


For Immediate Release:          
Monday, July 10, 2006

Lois Gibbs, CHEJ, 703-627-9483 (Cell)
Dr. Richard Clapp, B.U. School of Public Health, 617-638-4731 or 617-638-4620

National Academies New Study Concludes Dioxin is Toxic
5th Review of 15 Year-Long Delayed Study Finds Widely Disbursed Chemical
Causes Cancer, Developmental Problems & Birth Defects

The National Academies (NA) will release a controversial report on Tuesday confirming what numerous scientific panels have concluded over the past 15 years: dioxin is a potent cancer-causing chemical. Chlorine-based industries have been effectively stalling the release of the EPA's controversial dioxin reassessment for 15 years.  Dioxin can cause developmental and immune effects at levels close to those currently found in the general population. Every American eats dioxin when they consume fatty foods, and nearly every American has measurable levels of this chemical in their body.

"Although the NA review has confirmed that dioxin is a carcinogen, the EPA Dioxin Reassessment concluded this several years ago and recent studies have added additional weight to this conclusion," stated Dr. Richard Clapp, Professor of Environmental Health at Boston University School of Public Health.  "Furthermore, there does not appear be safe 'threshold' for dioxin's carcinogenic effects.  Evidence has accumulated since EPA began its reassessment in 1991 that dioxin also causes many other health problems even at low levels, such as developmental problems in children, immunologic problems in children and adults, reproductive problems in adults, and diabetes."

"The first health assessment of dioxin was in 1985," said Lois Gibbs, CHEJ Executive Director.  Gibbs's struggle to clean up dioxin in her Niagara Falls NY community at Love Canal has been credited with launching the grassroots environmental health movement. "Over the past 21 years, chlorine-based industries have demanded reviews, reassessments and analysis.  Each re-assessment and review affirmed the findings and newer scientific data continues to strengthen the conclusions that dioxin is a serious public health threat. The chlorine-based industry is following the tobacco industry's strategies to keep information from the public. Enough is enough-let's get on with establishing health protective regulations around dioxin discharges and clean ups," said Gibbs.

Dioxin is a known human carcinogen, active in the body at very small levels. Scientists at the Environmental Protection Agency (EPA) have long concluded dioxin and dioxin like compounds are highly toxic, but a strong coalition of industries responsible for generating the byproduct toxicant have successfully stalled progress on a 15-year study of the chemical. The EPA study-called the "Dioxin Reassessment"-still remains a draft, which has stymied the agency's development of federal regulations.  However, EPA recently set a major precedent when they set the soil cleanup goal for dioxin at 30 parts per trillion (ppt) at the Escambia Wood Treating Co. Superfund site in Pensacola, FL.

"While the Government studies this chemical for 15 years another generation of children are being raised surrounded by land saturated with dioxin. It's in their homes, yards, parks, gardens, fish, and river" said, Michelle Hurd Riddick of the Lone Tree Council, an environmental watch dog group pushing for cleanup of Dow Chemical's dioxin contamination in the Saginaw Bay Watershed of Michigan. "How many more reviews are we going to have? Dow keeps creating a  smokescreen to confuse people about the toxicity of dioxin.  It's time to finalize this report and end the delays that threaten public health."

Dow Chemical Company has been particularly aggressive in denying the toxicity of dioxin. The company's product line, which is heavily reliant on chlorinated chemical production, has resulted in communities contaminated with dioxin. Dow faces major liability for dioxin at its global headquarters in Michigan where the company has contaminated more than 50 miles of a river system that leads to Lake Huron, one of the Great Lakes. The company has repeatedly attempted to weaken cleanup standards to reduce the company's liability, while helping to create uncertainty at the federal level.  The company has fought the state residential cleanup standard in Michigan, which is 90 ppt, although the federal government recently used 30 ppt for a site in Florida.

The NA review was the result of a last minute amendment to the 2003 EPA appropriations bill, which required NA to review EPA's reassessment if a White House interagency task force did not reach consensus on its review of the draft report.  This NA review is the latest in a series of reviews largely orchestrated by the powerful set of industries that generate dioxin including some chemical manufacturers, pulp and paper companies, smelting and incinerator companies.

"The fingerprints of the chlorine-based industry have been evident in earlier scientific reviews, and there is concern about this review as well," said Stephen Lester, CHEJ Science Director. "In past reviews a major point of debate advocated by dioxin generating industries has been the use of a model to calculate cancer risk that assumes some dioxin exposures are too small to cause harm-a dangerous approach which EPA has repeatedly rejected in the past.  The debate over the validity of this model has been injected into every review for over 18 years by dioxin-generating industries and has led to repeated delays in finalizing the report."

Dioxin contamination is particularly high in areas with dioxin sources like incinerators, smelters, pulp and paper mills, chemical factories or other industries that use chlorine.  The disposal of polyvinyl chloride (PVC) plastic is the largest source of dioxin-forming chlorine in solid waste.  PVC is the leading contributor of chlorine to four combustion sources- municipal solid waste incinerators, backyard burn barrels, medical waste incinerators and secondary copper smelters-that account for an estimated 80% of dioxin air emissions.  Residents living near PVC chemical plants in Mossville, LA had three times more dioxin in their blood than the average U.S. citizen.   Dioxin has been found at hundreds of Superfund toxic waste sites. It was a contaminant in Love Canal, and Agent Orange, the herbicide sprayed in Vietnam that resulted in major health impacts for Vietnam Veterans. Dioxin has been found in milk, cheese, beef, pork, fish, chicken, birds, deer, turkey, squirrel, and worms, as well as soil and sewage sludge.

For more information, see "Chronological History of US EPA's Public Health Assessment of Dioxin" and "Dioxin Fact Sheet" at

Mike Schade
PVC Campaign Coordinator
Center for Health, Environment and Justice
9 Murray Street, Floor 3, New York, NY 10007-2223
Phone: (212) 964-3680
Fax: (212) 349-1366

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7/10/06 NAS report on EPA's Draft Dioxin Risk Assessment to be released to public 7/11/06

A new report from the National Academies' National Research Council, will be released at one-hour public briefing on Tuesday, July 11. Dioxin and dioxin-like compounds, released into the environment by industrial processes and present in the food chain, have been a concern since they were found in the herbicide Agent Orange. The new report examines the scientific soundness of the data, assumptions, and methods used in a draft reassessment of the health risks of dioxin issued by the U.S. Environmental Protection Agency in 2003. The report also looks at how uncertainties were factored into the reassessment.

Briefing details:
Tuesday, July 11, at 11 a.m. in the Lecture Room of the National Academies building, 2100 C St., N.W., Washington, D.C. Those who cannot attend may listen to a live audio webcast and submit questions by e-mail at

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bulletSee newspaper articles for information dating back to January 2002.  Click here
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